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A{.~ · A{.~ BEFORE THE BOARD OF PHARMACY DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA . In the Matter of the Accusation Against: …

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A~

BEFORE THE BOARD OF PHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Against

RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 Pharmacy Permit No PHY 42331

ANNE CHON-YIN CHUNG 3782 Moore Street Los Angele~ CA 90066 Original Pharmacist License No RPH 40932

Respondents

Case No 4775

OAH No 2014090139

STIPULATED SETTLEMENT AND DISCIPLINARY ORDER AS TO ANNE CHON-YIN CHUNG ONLY

DECISION AND ORDER

The attached Stipulated Settlement and Disciplinary Order is hereby adopted by the

Board of Pharmacy Department of Consumer Affairs as its Decision in this matter

middotThis decision shall become effective on December 8 2014

It is so ORDERED on November 262014

BOARD OF PHARMACY DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

By STAN C WEISSER Board President

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KAMALA D HARRIS Attorney General of California MARC D GREENBAUM Supervising Deputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207

300 So Spring Street Suite 1702 Los Angeles CA 90013 middot Telephone (213) 897-2564 Facsiinile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OFPHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Against RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 Pharmacy Permit No PHY 42331

ANNE CHON-YIN CHUNG 3782 Moore Street Los Angeles CA 90066

Original Pharmacist License No RPH 40932

Respondents

Case No 4775

OAH No 2014090139

STIPULATED SETTLEMENT ANDDISCIPLINARYmiddotORDER AS TO ANNECHON-YIN CHUNG ONLY

IT IS HEREBY STIPULATED AND AGREED by and between the parties to the above-

entitled proceedings that the following matters are 1Tue

PARTIES

1 Virginia Herold (Complainant) is the Executive Officer of the Board of Pharmacy

She brought this action solely in her official capacity and is represented in this matter by Kamala

D Harris Attorney General of the State of California by Gillian E Friedman Deputy Attorney

General

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STIPULATED SETTLEMENT (4775)

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2 Respondent Anne Chon-Yin Chung aka Anne Chung (Respondent Chung) is -middot - ~ middot-- ------ -

represented in this proceeding by attorney Benjamin Robert Margolis whose address is 1387

Monument Street Pacific Palisades CA 90272-2544

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932 to Anne Chon-Yin Chung aka Anne Chung The Original Pharmacist

License was in full force and effect at all times relevant to the charges brought herein and will

expire on Januruy 31 2015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Rite Aid Pharmacy 5429 located at 500 S Broadway Los Angeles California 90013-2302

Respondent Chung was removed as Pharmacist in Charge of Rite Aid Pharmacy 5429 on or

about September 5 2014

JURISDICTION

5 Accusation No 4775 was filed before the Board of Pharmacy (Board) Department

of Consumer Affairs and is cunently pending against Respondent Chung The Accusation and

all other statutorily required documents were properly served on Respondent Chung on April 4

2014 Respondent Chung timely filed her Notice of Defense contesting the Accusation

6 A copy _of Accusation No 4775 is attached as exhibit A and incorporated herein by

reference

ADVISEMENT AND WAIVERS

7 Respondent Chung has carefully read fully discussed with counsel and understands

the charges and allegations in Accusation No 4775 Respondent Chung has also carefully read

fully discussed withcounsel and understands the effects of this Stipulated Settlement and

Disciplinary Order

8 Respondent Chung is fully aware of her legal rights in this matter including the right

to a hearing on the charges and allegations in the Accusation the right to be represented by

counsel at her own expense the right to confront and cross-examine the witnesses against her the

right to present evidence and to testify on her own behalf the right to the issuance of subpoenas

to compel the attendance of witnesses and the production of documents the right to

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STIPULATED SETTLEMENT (4775)

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reconsideration and court review of an adverse decision and all other rights accorded by the

California Administrative Procedure Act and other applicable laws

9 Respondent Chtmg voluntarily knowingly and intelligently waives and gives up each

and every right set forth above

CULPABILITY

10 Respondent Chung understands and agrees that the charges and allegations in

Accusation No 4 775 if proven at a hearing constitute cause for imposing discipline upon her

Original PhaJmacy License

11 For the purpose of resolving the Accusation without the expense and uncertainty of

further proceedings Respondent Chung agrees that at a hearing Complainant could establish a

factual basis for the charges in the Accusation and that Respondent Chung hereby gives up her

right to contest those charges

-12 Respondent Chung agrees that her Original Pharmacist License is subject to

discipline and she agrees to be bound by the Boards probationary terms as set forth in the

Disciplinary Order below

CONTINGENCY

13 This stipulation shall be subject to approval by the Board of Pharmacy Respondent

Chung understands and agrees that counsel for Complainant and the staff of the Board of

Pharmacy may communicate directly with the Hoard regarding this stipulation and settlement

without notice to or participation by Respondent Chung or her counsel By signing the

stipulation Respondent Chung understands and agrees that she may not withdraw her agreement

or seek to rescind the stipulation pri01to the time the Board considers and acts upon it If the

Board fails to adopt this stipulation as its Decision and Order the Stipulated Settlement and

Disciplinary Order shall be of no force or effect except for this paragraph it shall be inadmissiblemiddot

in any legal action between the parties and the Board shall not be disqualified from further action

by having considered this matter

STIPULATED SETTLEMENT (4775)

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14 The parties understand and agree that Portable middotDocument Format (PDF) and facsimile - middot _ - bull --

copies of this Stipulated Settlement and Disciplinary Order including Portable Document Format

(PDF) and facsimile signatures thereto shall have the same force and effeCt as the originals

15 This Stipulated Settlement and Disciplinary Order is intended by the parties to bean

integrated writing representing the complete final and exclusive embodiment of their agreement

It supersedes any and all prior or contemporaneous agreements understandings discussions

negotiations and commitments (written or oral) This Stipulated Settlement and Disciplinary

Order may not be altered amended modified supplemented or middototherwise changed except by a

writing executed by an authorized representative of each of the parties

16 In consideration of the foregoing admissions and stipulations the parties agree that

the Board may without fmiher notice or formal proceeding issue and enter the following

Disciplinary Order

DISCIPLINARY ORDER

IT IS HEREBY ORDERED that Original Pharmacist License No RPH 40932 issued to

Respondent Anne Chon-Yin Chung (Respondent Chung) is revoked However the revocation is

stayed and Respondent Chung is placed on probation for five (5) years on the following terms and

conditions

1 Suspension

As part of probation Respondent Chung is suspended from the practice of pharmacy for

pinety (20_) dyS beginni-g tlJ~ effective dateCf~~is 4ecis~on

During suspension Respondent Chung shall not enter any pharmacy area or any portion of

the licensed premises of a wholesaler veterinary food-animal drug retailer or any other distributor

of drugs which is licensed by the board or any manufacturer or where dangerous drugs and

devices or controlled substances are maintained Respondent Chung shall not practice pharmacy

nor do any act involving drug selection selection of stock manufacturing compounding

dispensing or patient consultation nor shall Respondent Chung 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 and devices or controlled substances

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STIPULATED SETTLEMENT ( 4 775)

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Respondent Chung shall not engage in any activity that requires the professionll judgment bullbull middotmiddotmiddotmiddotbull -~middotmiddotmiddot bull middotbullbull bull bull bull bull bull bull bull bull bull -middot bull - bull middot-middot bull bull bull bull

of a pharmacist Respondent Chung shall not direct or control any aspect of the practice of

phannacy Respondent Chung shall not perform the duties of a pharmacy technician or a

designated representative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in aliy licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwise speCified in this order

Failure to comply with this suspension shall be considered a violation of probation

2 Obey All Laws

Respondent Chung shall obey all state and federal laws and regulations

Respondent Chung shall report any of the following occurrences to the board in writing

within seventy-two (72) hours of such occunence

bull an anest or issuance of a criminal complaint for violation of any provision of the

Pharmacy Law state and federal food and drug laws or state and federal controlled

substances laws

bull a plea of guilty or nolo contendre in any state or federal criminal proceeding to any

criminal complaint information or indictment

bull a conviction of any crime

discipline citation or other administrative action filed by any state or federal agency

which involves Respondent Chungs Pharmacist License or which is related to the

practice of pharmacy or the manufacturing obtaining handling distributing billing

or charging for any drug device or controlled substance

Failure to timely report such occurrence shall be considered middota violation of probation

3 Report to the Board

Respondent Chung shall ryport to the board quarterly on a schedule as directed by the

board or its designee The report shall be made either in person or in writing as directed Among

other requirements Respondent Chung shall state in each report under penalty of perjury whether

there has been compliance with all the terms and conditions of probation Failure to submit

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STIPULATED SETTLEMENT (4775)

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_fmely reports in a f~rrn a~ directed shall be considered a violation ofprobation Any period(s) of middot- bull middotmiddotmiddot-middot middot- middot middot-

delinquency in submission of reports as directed may be added to the total period of probation

Moreover if the final probation report is not made as directed probation shall be automatically

extended w1til such time as the final report is made and accepted by the board

4 Interview with the Board

Upon receipt of reasonable prior notice Respondent Chung shall appear in person for

interviews with the board or its designee at such intervals and locations as are determined by the

board or its designee Failure to appear for any scheduled interview without prior notification to

board staff or failure to appear for two (2) or more scheduled interviews with the board or its

designee during the period of probation shall be considered a violation of probation

5 Cooperate with Board Staff

Respondent Chung shall cooperate with the boards inspection program and with the boards

monitoring and investigation of Respondent Chungs compliance with the terms and conditions of

her probation Failure to cooperate shall be considered a violation of probation

6 Continuing Education

Respondent Chung shall provide evidence of efforts to maintain skill and knowledge as a

pharmacist as directed by the board or its designee

7 Notice to Employers

During the period of probation Respondent Chung shall notify all present and prospective

employers of the decision in case number 4775 and the terms conditions and restrictions imposed

on Respondent Chung by the decision as follows

Within thirty (30) days ofthe effective date ofthis decision and within fifteen (15) days of

Respondent Chtmg undertaking any new employment Respondent Chung shall cause her direct

supervisor pharmacist-in-charge (including each new pharmacist-in-charge employed during

Respondent Chung s tenure of employment) and owner to report to the board in writing

acknowledging that the listed individual(s) hashave read the decision in case number 4775 and

terms and conditions imposed thereby It shall be Respondent Chungs responsibility to ensure

that her employer(s) andor supervisor(s) submit timely acknowledgment(s) to the board

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STIPULATED SETTLEMENT (4775) I

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-~

Ill

Ill

-middot~-Jf)3~e_spo_rA~ntChl1ng V~rlcs for_or is ~mploye~ b)or tlyough (l Jh~JEaCY eJ11ployment

service Respondent Chung must notify her direct supervisor phannacist-in-charge and owner at

every entity ~icensed by the board of the terms arid conditions of the decision in case number

4775 in advance of the Respondent Chung commencing work at each licensed entity A record of

this notification mustbe provided to the board upon request

Furthemore within thiliy (30) days ofthe effective date of this decision and within fifteen

(15) days of Respondent Chung undertaking any Hew employment by or through a pharmacy

employment service Respondent Chlmg shall cause her direct supervisor with the pharmacy

employment service to report to the board in writing acknowledging that she has read the decision

in case number 4775 and the terms and conditions imposed thereby It shall be Respondent

Chlings respmisibility to ensure that her employer(s) andor supervisor(s) submit timely

acknowledgment(s) to the board

Failure to timely notify present or prospective employer(s) or to cause thatthose

employer(s) to submit timely acknowledgments to the board shall be considered a violation of

probation

Employment within the meaning of this provision shall include any full-time

pali-time temporary relief or pharmacy management service as a pharmacist or any

position for which a pharmacist license is a requirement or criterion for employment

whether the Respondent Chung is an employee independent contractor or volunteer

8 No Supervision oflnterns Serving as Pharmacist-in-Charge (PIC) Serving as Designated Representative-in-Charge or Serving as a Consultant

During the period of probation R~spondent Chlmg shall not supervise any intern

pharmacist be the pharmacist-in-charge or designated representative-in-charge of any entity

licensed by the board nor serve as a consultant unless otherwise specified in this order

Assumption of any such unauthorized supervision responsibilities shall middotbe considered a violation

of probation

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STIPULATED SETTLEMENT (4775)

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9 Reimbursement of Board Costs

As a condition precedent to successful completion of probation Respondent Chung shall

pay to the board its costs of investigation and prosecution in the amount of $826533

Respondent Chung shall make said payment on a payment plan approved by the board

There shall be no deviation from this schedule absent prior written middotapproval by the board or

its designee Failure to pay costs by the deadline(s) as directed shall be considered a violation of

probation

The filing of bankruptcy by Respondent Chung shall not relieve Respondent Chung of her

responsibility to reimburse the board its costs of investigation and prosecution

10 Probation Monitoring Costs

Respondent Chung shall pay any costs associated with probation monitoring as determined

by the board each and every year of probation Such costs shall be payable to the board on a

schedule as directed by the board or its designee Failure to pay such costs by the deadline(s) as

directed shall be considered a violation of probation

11 Status of License

Respondent Chung shall at all times while on probation maintain an active current license

with the boaid including any period during which suspension or probation is tolled Failure to

maintain an active current license shall be considered a violation of probation

IfRespondent ChLmg1s license expires or is cancelled by operation of law or otherwise at

any time during the period of probation including any extensions thereof due to tolling or

otherwise upon renewal or reapplication Respondent Chung1s license shall be subject to all terms

and conditions of this probation not previously satisfied

12 License Surrender While on ProbationSuspension

Following the effective date of this decision should Respondent Chung cease practice due

to retirement or health or be otherwise unable to satisfy the terms and conditions ofprobatiori

Respondent Chung maytender her license to the board for surrender The board or its designee

shall have the discretion whether to grant the request for surrender or take any other action it

deems appropriate and reasonable Upon formal acceptance of the surrender of the license

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STIPULATED SETTLEMENT ( 4 775)

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~~~E~-~d~n~__ ghu~will P-0 lltn~er be subject to ~e ~rrns an~ cndii_ol~ ofpro~a~ion This

surrender constitutes a record of discipline and shall become a part of the Respondent Chungs

license history with the board

Upon acceptance of the surrender Respondent Chung shall relinquish her pocket and wall

license to the board within ten ( 1 0) middotdays of notification by the board that the surrender is

accepted Respondent Chung may not reapply for any license from the board for three (3) years

from the effective date of the surrender Respondent Chung shall meet all requirements

applicable to the license sought as of the date the application for that license is submitted to the

board including any outstanding costs

13 Notification of a Change in N arne Residence Address Mailing Address or Employment middot

Respondent Chung shall notify the hoard in writing within ten (10) days of any change of

employment Said notification shall include the reasons for leaving the address of the new

~mployer the name ofthe supervise and owner and the work schedule ifknown Respondent

Chung shall further notify the board in writing within ten (1 0) days of a change in name

residence address mailing address or phone number

Failure to timely notify the board of any change in employer(s) name(s) address(es) or

phone number( s) shall be considered a violation of probation

14 Tolling of Probation

Except during periods of suspension Respondent Chung shall at all times while on

probation be employed as a pharmacist in California for a minimum of 40 hours per calendar

month Any month during which this minimum is not met shall toll the period of probation ie

the period ofpimiddotobation shall be extended by one month for each month during which this

minimum is not met During any such period oftolling of probation Respondent Chung must

nonetheless comply with all terms and conditions of probation

Should Respondent Chung regardless of residency for any reason (including vacation)

cease practicing as a pharmacist for a minimum of 40 hours per calendar month in California

Respondent Chung must notify the board in writing within ten (1 0) days of the cessation of

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STIPULATED SETTLEMENT ( 4775)

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practice and must further notify the board in writing within ten (1 0) days of the resumption of middotmiddot-middot -~ __ -- middot---middot- ~--

practice Any failure to provide such notification(s) shall be considered a violation of probation

It is a violation ofprobation for Respondent Chung1s probation to remain tolled pursuant to

the provisions of this condition for a total period counting consecutive and non-consecutive

months exceeding thirty-six (36) months

Cessation of practice means any cale~dar month during which Respondent

Chung is not practicing as a pharmacist for at least 40 hours as defined by Business

and Professions Code section 4000 et seq Resumption of practice means any

calendar month during which Respondent Chung is practicing as a pharmacist for at

least 40 hours as a pharmacist as defined by Business and Professions Code section

4000 et seq

15 Violation of Probation

If a Respondent Chung has not complied with any term or condition of probation the board

shall have continuing jurisdiction over Respondent Chung and probation shall automatically be

extended until all terms and conditions have been satisfied 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 that was stayed

If Respondent Chung violates probation in any respect the board after giving Respondent

Chung notice and an opportunity to be heard may revoke probation and carry out the disciplinary

order that was stayed Notice and opportunity to be heard are not required for those provisions

stating that a violation thereof may lead to automatic termination of the stay andor revocation of

the license If a petition to revoke probation or an accusation is filed against Respondent Chung

during probation the board shall have continuing jurisdiction and the period of probation shall be

automatically extended until the petition to revoke probation or accusation is heard and decided

16 Completion ofProbation

Upon written notice by the board or its designee indicating successful completion of

probation Respondent Chungs license will be fully restored

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STIPULATED SETTLEMENT (4775)

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17 Community Services Program middotmiddot--middot bull bullbull-bull _H_ bullI bull bullmiddotmiddotmiddotmiddotmiddot-~ bullmiddotbullbullo-middot bull bull~--middotmiddot-~---middotbull-bull~--bull-bullgtmiddotmiddot middotmiddotmiddotgtbull-bullmiddotbull -

Vilithin sixty (60) days of the effective date of this decision Respondent Chung shall submit

to the board or its designee for prior approval a community service program in which

Respondent Chung shall provide free health-care related services on a regular basis to a

middot

middot

community or charitable facility or agency foimiddot at least 64 hours per year for each year of

probation Within thirty (30) days ofboard approval thereof Respondent Chung shall submit

documentation to the board demonstrating commencement of the community service program A

record ofthis notification must be provided to the board upon request Respondent Chung shall

report on progress with the community service program in the quarterly reports Failure to timely

submit con1inenceor comply witi1 the program shall be considered a violation of probation

18 Remedial Education

Yfithin sixty (60) days of the effective date ofthis decision Respondent Chung shall submit

to the board or its designee for prior approval an appropriate program of remedial education

related to dispensing of controlled substances corresponding responsibility and appropriate

controlled substance therapy The program of remedial education shall consist of at least ten (1 0)

units which shall be completed within the first three years of probation at Respondent Chung1s

own expense All remedial education shall be in addition to and shall not be credited toward

continuing education (CE) courses used for license renewal purposes

Failure to timely submit or complete the approved remedial education shall be considered a

violation of probation The period of probation will be automatically extended until such

remedial education is successfully completed and writte1i proof in a form acceptable to the board

is provided to the board or its designee

Following the completion of each course the board or its designee may require the

Respondent Chung at her own expense to take an approved examination to test the Respondent

Chung1s knowledge of the course If the Respondent Chung does not achieve a passing score on

the examination this failure shall be considered a violation ofprobation Any such examination

failure shall require Respondent Chung to take another course approved by the board in the same

subject area

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STIPULATED SETTLEMENT (4775) I

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19 Supervised Practi(e

During the period of probation Respondent Chung shall practice only under the supervision

of a licens~d pharmacist not on probation with the board Upon and after the effective date of this

decision Respondent Chung shall not practice pharmacy and her license shall be automatically

suspended until a supervisor is approved by the board or its designee The supervision shall be

as required by the board or its designee either

Continuous- At least 75 of a work week

Substantial - At least 50 of a wotk week

Partial- At least 25 of a work week

Daily Review- Supervisor1s review of probationer1S daily activities within 24 hours

Within thirty (30) days ofthe effective date of this decision Respondent Chung shall have

her supervisor submit notification to the board in writing stating that the supervisor has read the

decision iri case number 4775 and is familiar with the required level of supervision as determined

by the board or its designee It shall be the Respondent Chungs responsibility to ensme that her

employer(s) pharmacist-in-charge andor supervisor(s) submit timely acknowledgement(s) to the

board Failure to cause the direct supervisor and the pharmacist-in-charge to submit timely

acla1owledgements to the board shall be considered a violation of probation

If Respondent Chung changes employment it shall be the Respondent Chung s

responsibility to ensure that her employer(s) pharmacist-in-charge andor supervisor(s) submit

timely acknowledgement(s) to the board Respondent Chung shall have her new supervisor

within fifteen (15) days after employment commences submit notification to the board in writing

stating the direct supervisor and pharmacist-in-charge have read the decision in case number 4775

and is familiar with the level of supervision as determined by the board Respondent Chung shall

not practice pharmacy and her license shall be automatically suspended until the board or its

designee approves a new supervisor Failure to cause the direct supervisor and the phannacist-inshy

charge to submit timely acknowledgements to the board shall be considered a violation of

probation

Within ten (1 0) days of leaving employment Respondent Chung shall notify the board in

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STIPULATED SETTLEMENT (4775)

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writing

During suspension Respondent Chung shall not enter any pharmacy area or any portion of

the licensed premises of a wholesaler veterinary food-animal drug retailer or any other distributor

of drugs which is licensed by the board or any manufacturer or where dangerous drugs and

devices or controlled substances are maintained Respondent ChtmgBhallmiddotnotpractice pharmacy

nor do any act involving drug selection selection of stock manufacturing compounding

dispensing or patient consultation nor shall Respondent Chung 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 and controlled substances Respondent Chung shall not resume

practice until notified by the board

During suspension Respondent Chung shall not engage in any activity that requires the

professional judgment of a pharmacist Respondent Chung shall not direct or control any aspect

of the practice of pharmacy Respondent Chung shall not perform the duties of a pharmacy

technician or a designatedrepresentative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in arty licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwisespecified in thismiddot order

Failure to comply with this suspension shall be considered a violation of probation

20 No Ownership of Licensed Premises

Respondent Chung shall not own have any legal or beneficial interest in or serve as a

manager administrator member officer director trustee associate or partner of any business

firm pruinership or corporation currently or hereinafter licensed by the board Respondent

Chung shall sell or transfer any legal or beneficial interest in any entity licensed by the board

within ninety (90) days followiiig the effective date of this decision and shallimmediately

thereafter provide written proof thereof to the borumiddotd Failure to timely divest any legal or

beneficial interest(s) or provide documentation thereof shall be considered a violation of

probation

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STIPULATED SETTLEMENT (4775) I

r-----------------------------------------middot-middotmiddotmiddot-middotmiddot -

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21 Tolling of Suspension

During the period of suspension respondent shall not leave California for any period

exceeding ten (10) days regardless of purpose (including vacation) Any such absence in excess

ofthe (10) days d11ring suspension shall be considered a violation of probation Moreover any

absence from California during the period of suspension exceeding ten (1 0) days shall toll the

suspension ie the suspension shall be extended by one day for each day over ten (10) days

respondent is absent from California During any such period of tolling of suspension respondent

must nonetheless comply with all terms m1d conditions of probation

Respondent must notify the bomd in writing within ten (1 0) days of departure and must

further notify the board in writing within ten (1 0) days of return The f~ilure to provide such

notification(s) shall constitute a violation ofprobation Upon such departure m1d return

respondent shall not resume the practice ofpharmacy until notified by the board that the period of

middotsuspension has been satisfactorily completed

ACCEPTANCE

I have carefully read the above Stipulated Settlement and Disciplinary Order and have fully

discussed it with my attorney Benjamin Robert Margolis I understm1d the stipulation m1d the

effect it will have on my Original Pharmacist License I enter into this Stipulated Settlement and

Disciplinary Order voluntarily knowingly and intelligently and agree to be bound by the

Decision and Order of the Bommiddotd of Pharmacy

DATED I Anne Chon-Yin Chun ka A1me Chung

of

I have read m1d fully discussed with Respondent Chung the terms and conditions and other

matters contained in the above Stipulated2ettlet and Disciplinary Or~~middot~r__approve its form

and content middot ---~ -shy

DATED joj j1y ~ ~~middot-- bull J J~nj airul1Kobert Margolis

Lttorney for Respondent Chung

14 STIPULATED SETTLEMENT (4775)

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ENDORSEMENT

The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully

submitted for consideration by the Board of Pharmacy

Dated D -I - ~ Respectfully submitted

KAMALA D HARRIS Attorney General of California MARC D GREENBAUM Supervising Deputy Atton1ey General

GILLIAN E FRIEDMAN Deputy Attorney General Attorneys for Complainant

LA2013509837 51608369doc

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STIPULATED SETTLEMENT (4775)

Exhibit A

Accusation No 4775

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KAMALA D HARRlS A ttomey General of California MARC D GREENBAUM SuperVisingDeputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207 middot 300 So Spring Street Suite 1702

Los Angeles CA 90013 Telephone (213)897-2564 Facsimile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OF PHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Again~t

RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 PharmacyPermit No PHY 42331

ANNE CHON-YIN CHUNG 3 782 Moore Street Los Angeles CA 90066 Original Pharmacist License No RPH 40932

Respondents

Case No 4775

ACCUSATION

Complainant alleges

PARTIEsmiddot

1 Virginia Herold (Complainant) brings this Accusation solely in her official capacity

as the Executive Officer ofthe Board ofPharmacyDepartment of Consumer Affa)rs

2 On or about February 21 1997 the Board of Pharmacy issued Pharmacy Permit

Number PHY 42331 to Rite Aid 5429 located at 500 S Broadway Los Angeles California

90013-2302 (Respondent Rite Aid Pharmacy) The Pharmacy Permit was in full force and effect

Accusation

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at all times relevant to the charges brought herein and will expire on April 1 2014 unless

renewed

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932to Anne Chon-Yin Chu11g aka Anne Chung (Respondent Chung) The

Original Pharmacy License was in full force and effect at all times relevant to the charges brought

herein and will expire on January 312015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Respondent Rite Aiel Pharmacy

JURISDICTION

5 This Accusation is brought before the Board ofPharmacy (Board) Department of

Consumer Affairs under the authority onhe following laws All section references are to the

Business and Professions Code unless otherwise indicated

6 Section 4300 ofthe Code states

(a) Every license issued may be suspended or revoked

7 Section 4301 ofthe Code states

The board shall take action against any holder of a license who is guilty of unprofessional

conduct or whose license has been procured byfraud or misrepresentation or issued by mistake

Unprofessional conduct shall include but is not limited to any of the following

(a) Gross immorality

(b) Incompetence

(c) Gross negligence

(d) The clearly excessive furnishing of controiled substances in violation of subdivision (a)

of Section 11153 of the Health and Safety Code

(e) The cearly ~xces~iye furnishing of controlled substances in viqlation of subdivisiol (a)

of Section 111535 of the Health and Safety Code Factors to be considered in determining

whether the furnishing of controlled substances is clearly excessive shall include but not be

limited to the amount of controlled substances furnished the previous ordering pattern of the

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Accusation

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customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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Accusation

(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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Accusation I

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

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21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

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Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

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a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

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d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

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supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

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r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

f4

16

17

18

19

21

22

middot 23

24

26

27

28

e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

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middot17

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middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

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y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

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f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

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middot 23

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

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i i I

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middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

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middot

KAMALA D HARRIS Attorney General of California MARC D GREENBAUM Supervising Deputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207

300 So Spring Street Suite 1702 Los Angeles CA 90013 middot Telephone (213) 897-2564 Facsiinile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OFPHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Against RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 Pharmacy Permit No PHY 42331

ANNE CHON-YIN CHUNG 3782 Moore Street Los Angeles CA 90066

Original Pharmacist License No RPH 40932

Respondents

Case No 4775

OAH No 2014090139

STIPULATED SETTLEMENT ANDDISCIPLINARYmiddotORDER AS TO ANNECHON-YIN CHUNG ONLY

IT IS HEREBY STIPULATED AND AGREED by and between the parties to the above-

entitled proceedings that the following matters are 1Tue

PARTIES

1 Virginia Herold (Complainant) is the Executive Officer of the Board of Pharmacy

She brought this action solely in her official capacity and is represented in this matter by Kamala

D Harris Attorney General of the State of California by Gillian E Friedman Deputy Attorney

General

1

STIPULATED SETTLEMENT (4775)

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2 Respondent Anne Chon-Yin Chung aka Anne Chung (Respondent Chung) is -middot - ~ middot-- ------ -

represented in this proceeding by attorney Benjamin Robert Margolis whose address is 1387

Monument Street Pacific Palisades CA 90272-2544

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932 to Anne Chon-Yin Chung aka Anne Chung The Original Pharmacist

License was in full force and effect at all times relevant to the charges brought herein and will

expire on Januruy 31 2015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Rite Aid Pharmacy 5429 located at 500 S Broadway Los Angeles California 90013-2302

Respondent Chung was removed as Pharmacist in Charge of Rite Aid Pharmacy 5429 on or

about September 5 2014

JURISDICTION

5 Accusation No 4775 was filed before the Board of Pharmacy (Board) Department

of Consumer Affairs and is cunently pending against Respondent Chung The Accusation and

all other statutorily required documents were properly served on Respondent Chung on April 4

2014 Respondent Chung timely filed her Notice of Defense contesting the Accusation

6 A copy _of Accusation No 4775 is attached as exhibit A and incorporated herein by

reference

ADVISEMENT AND WAIVERS

7 Respondent Chung has carefully read fully discussed with counsel and understands

the charges and allegations in Accusation No 4775 Respondent Chung has also carefully read

fully discussed withcounsel and understands the effects of this Stipulated Settlement and

Disciplinary Order

8 Respondent Chung is fully aware of her legal rights in this matter including the right

to a hearing on the charges and allegations in the Accusation the right to be represented by

counsel at her own expense the right to confront and cross-examine the witnesses against her the

right to present evidence and to testify on her own behalf the right to the issuance of subpoenas

to compel the attendance of witnesses and the production of documents the right to

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reconsideration and court review of an adverse decision and all other rights accorded by the

California Administrative Procedure Act and other applicable laws

9 Respondent Chtmg voluntarily knowingly and intelligently waives and gives up each

and every right set forth above

CULPABILITY

10 Respondent Chung understands and agrees that the charges and allegations in

Accusation No 4 775 if proven at a hearing constitute cause for imposing discipline upon her

Original PhaJmacy License

11 For the purpose of resolving the Accusation without the expense and uncertainty of

further proceedings Respondent Chung agrees that at a hearing Complainant could establish a

factual basis for the charges in the Accusation and that Respondent Chung hereby gives up her

right to contest those charges

-12 Respondent Chung agrees that her Original Pharmacist License is subject to

discipline and she agrees to be bound by the Boards probationary terms as set forth in the

Disciplinary Order below

CONTINGENCY

13 This stipulation shall be subject to approval by the Board of Pharmacy Respondent

Chung understands and agrees that counsel for Complainant and the staff of the Board of

Pharmacy may communicate directly with the Hoard regarding this stipulation and settlement

without notice to or participation by Respondent Chung or her counsel By signing the

stipulation Respondent Chung understands and agrees that she may not withdraw her agreement

or seek to rescind the stipulation pri01to the time the Board considers and acts upon it If the

Board fails to adopt this stipulation as its Decision and Order the Stipulated Settlement and

Disciplinary Order shall be of no force or effect except for this paragraph it shall be inadmissiblemiddot

in any legal action between the parties and the Board shall not be disqualified from further action

by having considered this matter

STIPULATED SETTLEMENT (4775)

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14 The parties understand and agree that Portable middotDocument Format (PDF) and facsimile - middot _ - bull --

copies of this Stipulated Settlement and Disciplinary Order including Portable Document Format

(PDF) and facsimile signatures thereto shall have the same force and effeCt as the originals

15 This Stipulated Settlement and Disciplinary Order is intended by the parties to bean

integrated writing representing the complete final and exclusive embodiment of their agreement

It supersedes any and all prior or contemporaneous agreements understandings discussions

negotiations and commitments (written or oral) This Stipulated Settlement and Disciplinary

Order may not be altered amended modified supplemented or middototherwise changed except by a

writing executed by an authorized representative of each of the parties

16 In consideration of the foregoing admissions and stipulations the parties agree that

the Board may without fmiher notice or formal proceeding issue and enter the following

Disciplinary Order

DISCIPLINARY ORDER

IT IS HEREBY ORDERED that Original Pharmacist License No RPH 40932 issued to

Respondent Anne Chon-Yin Chung (Respondent Chung) is revoked However the revocation is

stayed and Respondent Chung is placed on probation for five (5) years on the following terms and

conditions

1 Suspension

As part of probation Respondent Chung is suspended from the practice of pharmacy for

pinety (20_) dyS beginni-g tlJ~ effective dateCf~~is 4ecis~on

During suspension Respondent Chung shall not enter any pharmacy area or any portion of

the licensed premises of a wholesaler veterinary food-animal drug retailer or any other distributor

of drugs which is licensed by the board or any manufacturer or where dangerous drugs and

devices or controlled substances are maintained Respondent Chung shall not practice pharmacy

nor do any act involving drug selection selection of stock manufacturing compounding

dispensing or patient consultation nor shall Respondent Chung 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 and devices or controlled substances

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Respondent Chung shall not engage in any activity that requires the professionll judgment bullbull middotmiddotmiddotmiddotbull -~middotmiddotmiddot bull middotbullbull bull bull bull bull bull bull bull bull bull -middot bull - bull middot-middot bull bull bull bull

of a pharmacist Respondent Chung shall not direct or control any aspect of the practice of

phannacy Respondent Chung shall not perform the duties of a pharmacy technician or a

designated representative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in aliy licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwise speCified in this order

Failure to comply with this suspension shall be considered a violation of probation

2 Obey All Laws

Respondent Chung shall obey all state and federal laws and regulations

Respondent Chung shall report any of the following occurrences to the board in writing

within seventy-two (72) hours of such occunence

bull an anest or issuance of a criminal complaint for violation of any provision of the

Pharmacy Law state and federal food and drug laws or state and federal controlled

substances laws

bull a plea of guilty or nolo contendre in any state or federal criminal proceeding to any

criminal complaint information or indictment

bull a conviction of any crime

discipline citation or other administrative action filed by any state or federal agency

which involves Respondent Chungs Pharmacist License or which is related to the

practice of pharmacy or the manufacturing obtaining handling distributing billing

or charging for any drug device or controlled substance

Failure to timely report such occurrence shall be considered middota violation of probation

3 Report to the Board

Respondent Chung shall ryport to the board quarterly on a schedule as directed by the

board or its designee The report shall be made either in person or in writing as directed Among

other requirements Respondent Chung shall state in each report under penalty of perjury whether

there has been compliance with all the terms and conditions of probation Failure to submit

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_fmely reports in a f~rrn a~ directed shall be considered a violation ofprobation Any period(s) of middot- bull middotmiddotmiddot-middot middot- middot middot-

delinquency in submission of reports as directed may be added to the total period of probation

Moreover if the final probation report is not made as directed probation shall be automatically

extended w1til such time as the final report is made and accepted by the board

4 Interview with the Board

Upon receipt of reasonable prior notice Respondent Chung shall appear in person for

interviews with the board or its designee at such intervals and locations as are determined by the

board or its designee Failure to appear for any scheduled interview without prior notification to

board staff or failure to appear for two (2) or more scheduled interviews with the board or its

designee during the period of probation shall be considered a violation of probation

5 Cooperate with Board Staff

Respondent Chung shall cooperate with the boards inspection program and with the boards

monitoring and investigation of Respondent Chungs compliance with the terms and conditions of

her probation Failure to cooperate shall be considered a violation of probation

6 Continuing Education

Respondent Chung shall provide evidence of efforts to maintain skill and knowledge as a

pharmacist as directed by the board or its designee

7 Notice to Employers

During the period of probation Respondent Chung shall notify all present and prospective

employers of the decision in case number 4775 and the terms conditions and restrictions imposed

on Respondent Chung by the decision as follows

Within thirty (30) days ofthe effective date ofthis decision and within fifteen (15) days of

Respondent Chtmg undertaking any new employment Respondent Chung shall cause her direct

supervisor pharmacist-in-charge (including each new pharmacist-in-charge employed during

Respondent Chung s tenure of employment) and owner to report to the board in writing

acknowledging that the listed individual(s) hashave read the decision in case number 4775 and

terms and conditions imposed thereby It shall be Respondent Chungs responsibility to ensure

that her employer(s) andor supervisor(s) submit timely acknowledgment(s) to the board

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-~

Ill

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-middot~-Jf)3~e_spo_rA~ntChl1ng V~rlcs for_or is ~mploye~ b)or tlyough (l Jh~JEaCY eJ11ployment

service Respondent Chung must notify her direct supervisor phannacist-in-charge and owner at

every entity ~icensed by the board of the terms arid conditions of the decision in case number

4775 in advance of the Respondent Chung commencing work at each licensed entity A record of

this notification mustbe provided to the board upon request

Furthemore within thiliy (30) days ofthe effective date of this decision and within fifteen

(15) days of Respondent Chung undertaking any Hew employment by or through a pharmacy

employment service Respondent Chlmg shall cause her direct supervisor with the pharmacy

employment service to report to the board in writing acknowledging that she has read the decision

in case number 4775 and the terms and conditions imposed thereby It shall be Respondent

Chlings respmisibility to ensure that her employer(s) andor supervisor(s) submit timely

acknowledgment(s) to the board

Failure to timely notify present or prospective employer(s) or to cause thatthose

employer(s) to submit timely acknowledgments to the board shall be considered a violation of

probation

Employment within the meaning of this provision shall include any full-time

pali-time temporary relief or pharmacy management service as a pharmacist or any

position for which a pharmacist license is a requirement or criterion for employment

whether the Respondent Chung is an employee independent contractor or volunteer

8 No Supervision oflnterns Serving as Pharmacist-in-Charge (PIC) Serving as Designated Representative-in-Charge or Serving as a Consultant

During the period of probation R~spondent Chlmg shall not supervise any intern

pharmacist be the pharmacist-in-charge or designated representative-in-charge of any entity

licensed by the board nor serve as a consultant unless otherwise specified in this order

Assumption of any such unauthorized supervision responsibilities shall middotbe considered a violation

of probation

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9 Reimbursement of Board Costs

As a condition precedent to successful completion of probation Respondent Chung shall

pay to the board its costs of investigation and prosecution in the amount of $826533

Respondent Chung shall make said payment on a payment plan approved by the board

There shall be no deviation from this schedule absent prior written middotapproval by the board or

its designee Failure to pay costs by the deadline(s) as directed shall be considered a violation of

probation

The filing of bankruptcy by Respondent Chung shall not relieve Respondent Chung of her

responsibility to reimburse the board its costs of investigation and prosecution

10 Probation Monitoring Costs

Respondent Chung shall pay any costs associated with probation monitoring as determined

by the board each and every year of probation Such costs shall be payable to the board on a

schedule as directed by the board or its designee Failure to pay such costs by the deadline(s) as

directed shall be considered a violation of probation

11 Status of License

Respondent Chung shall at all times while on probation maintain an active current license

with the boaid including any period during which suspension or probation is tolled Failure to

maintain an active current license shall be considered a violation of probation

IfRespondent ChLmg1s license expires or is cancelled by operation of law or otherwise at

any time during the period of probation including any extensions thereof due to tolling or

otherwise upon renewal or reapplication Respondent Chung1s license shall be subject to all terms

and conditions of this probation not previously satisfied

12 License Surrender While on ProbationSuspension

Following the effective date of this decision should Respondent Chung cease practice due

to retirement or health or be otherwise unable to satisfy the terms and conditions ofprobatiori

Respondent Chung maytender her license to the board for surrender The board or its designee

shall have the discretion whether to grant the request for surrender or take any other action it

deems appropriate and reasonable Upon formal acceptance of the surrender of the license

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~~~E~-~d~n~__ ghu~will P-0 lltn~er be subject to ~e ~rrns an~ cndii_ol~ ofpro~a~ion This

surrender constitutes a record of discipline and shall become a part of the Respondent Chungs

license history with the board

Upon acceptance of the surrender Respondent Chung shall relinquish her pocket and wall

license to the board within ten ( 1 0) middotdays of notification by the board that the surrender is

accepted Respondent Chung may not reapply for any license from the board for three (3) years

from the effective date of the surrender Respondent Chung shall meet all requirements

applicable to the license sought as of the date the application for that license is submitted to the

board including any outstanding costs

13 Notification of a Change in N arne Residence Address Mailing Address or Employment middot

Respondent Chung shall notify the hoard in writing within ten (10) days of any change of

employment Said notification shall include the reasons for leaving the address of the new

~mployer the name ofthe supervise and owner and the work schedule ifknown Respondent

Chung shall further notify the board in writing within ten (1 0) days of a change in name

residence address mailing address or phone number

Failure to timely notify the board of any change in employer(s) name(s) address(es) or

phone number( s) shall be considered a violation of probation

14 Tolling of Probation

Except during periods of suspension Respondent Chung shall at all times while on

probation be employed as a pharmacist in California for a minimum of 40 hours per calendar

month Any month during which this minimum is not met shall toll the period of probation ie

the period ofpimiddotobation shall be extended by one month for each month during which this

minimum is not met During any such period oftolling of probation Respondent Chung must

nonetheless comply with all terms and conditions of probation

Should Respondent Chung regardless of residency for any reason (including vacation)

cease practicing as a pharmacist for a minimum of 40 hours per calendar month in California

Respondent Chung must notify the board in writing within ten (1 0) days of the cessation of

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practice and must further notify the board in writing within ten (1 0) days of the resumption of middotmiddot-middot -~ __ -- middot---middot- ~--

practice Any failure to provide such notification(s) shall be considered a violation of probation

It is a violation ofprobation for Respondent Chung1s probation to remain tolled pursuant to

the provisions of this condition for a total period counting consecutive and non-consecutive

months exceeding thirty-six (36) months

Cessation of practice means any cale~dar month during which Respondent

Chung is not practicing as a pharmacist for at least 40 hours as defined by Business

and Professions Code section 4000 et seq Resumption of practice means any

calendar month during which Respondent Chung is practicing as a pharmacist for at

least 40 hours as a pharmacist as defined by Business and Professions Code section

4000 et seq

15 Violation of Probation

If a Respondent Chung has not complied with any term or condition of probation the board

shall have continuing jurisdiction over Respondent Chung and probation shall automatically be

extended until all terms and conditions have been satisfied 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 that was stayed

If Respondent Chung violates probation in any respect the board after giving Respondent

Chung notice and an opportunity to be heard may revoke probation and carry out the disciplinary

order that was stayed Notice and opportunity to be heard are not required for those provisions

stating that a violation thereof may lead to automatic termination of the stay andor revocation of

the license If a petition to revoke probation or an accusation is filed against Respondent Chung

during probation the board shall have continuing jurisdiction and the period of probation shall be

automatically extended until the petition to revoke probation or accusation is heard and decided

16 Completion ofProbation

Upon written notice by the board or its designee indicating successful completion of

probation Respondent Chungs license will be fully restored

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17 Community Services Program middotmiddot--middot bull bullbull-bull _H_ bullI bull bullmiddotmiddotmiddotmiddotmiddot-~ bullmiddotbullbullo-middot bull bull~--middotmiddot-~---middotbull-bull~--bull-bullgtmiddotmiddot middotmiddotmiddotgtbull-bullmiddotbull -

Vilithin sixty (60) days of the effective date of this decision Respondent Chung shall submit

to the board or its designee for prior approval a community service program in which

Respondent Chung shall provide free health-care related services on a regular basis to a

middot

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community or charitable facility or agency foimiddot at least 64 hours per year for each year of

probation Within thirty (30) days ofboard approval thereof Respondent Chung shall submit

documentation to the board demonstrating commencement of the community service program A

record ofthis notification must be provided to the board upon request Respondent Chung shall

report on progress with the community service program in the quarterly reports Failure to timely

submit con1inenceor comply witi1 the program shall be considered a violation of probation

18 Remedial Education

Yfithin sixty (60) days of the effective date ofthis decision Respondent Chung shall submit

to the board or its designee for prior approval an appropriate program of remedial education

related to dispensing of controlled substances corresponding responsibility and appropriate

controlled substance therapy The program of remedial education shall consist of at least ten (1 0)

units which shall be completed within the first three years of probation at Respondent Chung1s

own expense All remedial education shall be in addition to and shall not be credited toward

continuing education (CE) courses used for license renewal purposes

Failure to timely submit or complete the approved remedial education shall be considered a

violation of probation The period of probation will be automatically extended until such

remedial education is successfully completed and writte1i proof in a form acceptable to the board

is provided to the board or its designee

Following the completion of each course the board or its designee may require the

Respondent Chung at her own expense to take an approved examination to test the Respondent

Chung1s knowledge of the course If the Respondent Chung does not achieve a passing score on

the examination this failure shall be considered a violation ofprobation Any such examination

failure shall require Respondent Chung to take another course approved by the board in the same

subject area

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19 Supervised Practi(e

During the period of probation Respondent Chung shall practice only under the supervision

of a licens~d pharmacist not on probation with the board Upon and after the effective date of this

decision Respondent Chung shall not practice pharmacy and her license shall be automatically

suspended until a supervisor is approved by the board or its designee The supervision shall be

as required by the board or its designee either

Continuous- At least 75 of a work week

Substantial - At least 50 of a wotk week

Partial- At least 25 of a work week

Daily Review- Supervisor1s review of probationer1S daily activities within 24 hours

Within thirty (30) days ofthe effective date of this decision Respondent Chung shall have

her supervisor submit notification to the board in writing stating that the supervisor has read the

decision iri case number 4775 and is familiar with the required level of supervision as determined

by the board or its designee It shall be the Respondent Chungs responsibility to ensme that her

employer(s) pharmacist-in-charge andor supervisor(s) submit timely acknowledgement(s) to the

board Failure to cause the direct supervisor and the pharmacist-in-charge to submit timely

acla1owledgements to the board shall be considered a violation of probation

If Respondent Chung changes employment it shall be the Respondent Chung s

responsibility to ensure that her employer(s) pharmacist-in-charge andor supervisor(s) submit

timely acknowledgement(s) to the board Respondent Chung shall have her new supervisor

within fifteen (15) days after employment commences submit notification to the board in writing

stating the direct supervisor and pharmacist-in-charge have read the decision in case number 4775

and is familiar with the level of supervision as determined by the board Respondent Chung shall

not practice pharmacy and her license shall be automatically suspended until the board or its

designee approves a new supervisor Failure to cause the direct supervisor and the phannacist-inshy

charge to submit timely acknowledgements to the board shall be considered a violation of

probation

Within ten (1 0) days of leaving employment Respondent Chung shall notify the board in

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writing

During suspension Respondent Chung shall not enter any pharmacy area or any portion of

the licensed premises of a wholesaler veterinary food-animal drug retailer or any other distributor

of drugs which is licensed by the board or any manufacturer or where dangerous drugs and

devices or controlled substances are maintained Respondent ChtmgBhallmiddotnotpractice pharmacy

nor do any act involving drug selection selection of stock manufacturing compounding

dispensing or patient consultation nor shall Respondent Chung 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 and controlled substances Respondent Chung shall not resume

practice until notified by the board

During suspension Respondent Chung shall not engage in any activity that requires the

professional judgment of a pharmacist Respondent Chung shall not direct or control any aspect

of the practice of pharmacy Respondent Chung shall not perform the duties of a pharmacy

technician or a designatedrepresentative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in arty licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwisespecified in thismiddot order

Failure to comply with this suspension shall be considered a violation of probation

20 No Ownership of Licensed Premises

Respondent Chung shall not own have any legal or beneficial interest in or serve as a

manager administrator member officer director trustee associate or partner of any business

firm pruinership or corporation currently or hereinafter licensed by the board Respondent

Chung shall sell or transfer any legal or beneficial interest in any entity licensed by the board

within ninety (90) days followiiig the effective date of this decision and shallimmediately

thereafter provide written proof thereof to the borumiddotd Failure to timely divest any legal or

beneficial interest(s) or provide documentation thereof shall be considered a violation of

probation

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STIPULATED SETTLEMENT (4775) I

r-----------------------------------------middot-middotmiddotmiddot-middotmiddot -

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21 Tolling of Suspension

During the period of suspension respondent shall not leave California for any period

exceeding ten (10) days regardless of purpose (including vacation) Any such absence in excess

ofthe (10) days d11ring suspension shall be considered a violation of probation Moreover any

absence from California during the period of suspension exceeding ten (1 0) days shall toll the

suspension ie the suspension shall be extended by one day for each day over ten (10) days

respondent is absent from California During any such period of tolling of suspension respondent

must nonetheless comply with all terms m1d conditions of probation

Respondent must notify the bomd in writing within ten (1 0) days of departure and must

further notify the board in writing within ten (1 0) days of return The f~ilure to provide such

notification(s) shall constitute a violation ofprobation Upon such departure m1d return

respondent shall not resume the practice ofpharmacy until notified by the board that the period of

middotsuspension has been satisfactorily completed

ACCEPTANCE

I have carefully read the above Stipulated Settlement and Disciplinary Order and have fully

discussed it with my attorney Benjamin Robert Margolis I understm1d the stipulation m1d the

effect it will have on my Original Pharmacist License I enter into this Stipulated Settlement and

Disciplinary Order voluntarily knowingly and intelligently and agree to be bound by the

Decision and Order of the Bommiddotd of Pharmacy

DATED I Anne Chon-Yin Chun ka A1me Chung

of

I have read m1d fully discussed with Respondent Chung the terms and conditions and other

matters contained in the above Stipulated2ettlet and Disciplinary Or~~middot~r__approve its form

and content middot ---~ -shy

DATED joj j1y ~ ~~middot-- bull J J~nj airul1Kobert Margolis

Lttorney for Respondent Chung

14 STIPULATED SETTLEMENT (4775)

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ENDORSEMENT

The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully

submitted for consideration by the Board of Pharmacy

Dated D -I - ~ Respectfully submitted

KAMALA D HARRIS Attorney General of California MARC D GREENBAUM Supervising Deputy Atton1ey General

GILLIAN E FRIEDMAN Deputy Attorney General Attorneys for Complainant

LA2013509837 51608369doc

15

STIPULATED SETTLEMENT (4775)

Exhibit A

Accusation No 4775

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KAMALA D HARRlS A ttomey General of California MARC D GREENBAUM SuperVisingDeputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207 middot 300 So Spring Street Suite 1702

Los Angeles CA 90013 Telephone (213)897-2564 Facsimile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OF PHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Again~t

RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 PharmacyPermit No PHY 42331

ANNE CHON-YIN CHUNG 3 782 Moore Street Los Angeles CA 90066 Original Pharmacist License No RPH 40932

Respondents

Case No 4775

ACCUSATION

Complainant alleges

PARTIEsmiddot

1 Virginia Herold (Complainant) brings this Accusation solely in her official capacity

as the Executive Officer ofthe Board ofPharmacyDepartment of Consumer Affa)rs

2 On or about February 21 1997 the Board of Pharmacy issued Pharmacy Permit

Number PHY 42331 to Rite Aid 5429 located at 500 S Broadway Los Angeles California

90013-2302 (Respondent Rite Aid Pharmacy) The Pharmacy Permit was in full force and effect

Accusation

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at all times relevant to the charges brought herein and will expire on April 1 2014 unless

renewed

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932to Anne Chon-Yin Chu11g aka Anne Chung (Respondent Chung) The

Original Pharmacy License was in full force and effect at all times relevant to the charges brought

herein and will expire on January 312015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Respondent Rite Aiel Pharmacy

JURISDICTION

5 This Accusation is brought before the Board ofPharmacy (Board) Department of

Consumer Affairs under the authority onhe following laws All section references are to the

Business and Professions Code unless otherwise indicated

6 Section 4300 ofthe Code states

(a) Every license issued may be suspended or revoked

7 Section 4301 ofthe Code states

The board shall take action against any holder of a license who is guilty of unprofessional

conduct or whose license has been procured byfraud or misrepresentation or issued by mistake

Unprofessional conduct shall include but is not limited to any of the following

(a) Gross immorality

(b) Incompetence

(c) Gross negligence

(d) The clearly excessive furnishing of controiled substances in violation of subdivision (a)

of Section 11153 of the Health and Safety Code

(e) The cearly ~xces~iye furnishing of controlled substances in viqlation of subdivisiol (a)

of Section 111535 of the Health and Safety Code Factors to be considered in determining

whether the furnishing of controlled substances is clearly excessive shall include but not be

limited to the amount of controlled substances furnished the previous ordering pattern of the

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customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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Accusation

(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

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21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

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Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

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a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

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d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

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supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

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r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

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1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

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e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

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1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

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18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

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26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

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y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

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f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

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middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

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2 Respondent Anne Chon-Yin Chung aka Anne Chung (Respondent Chung) is -middot - ~ middot-- ------ -

represented in this proceeding by attorney Benjamin Robert Margolis whose address is 1387

Monument Street Pacific Palisades CA 90272-2544

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932 to Anne Chon-Yin Chung aka Anne Chung The Original Pharmacist

License was in full force and effect at all times relevant to the charges brought herein and will

expire on Januruy 31 2015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Rite Aid Pharmacy 5429 located at 500 S Broadway Los Angeles California 90013-2302

Respondent Chung was removed as Pharmacist in Charge of Rite Aid Pharmacy 5429 on or

about September 5 2014

JURISDICTION

5 Accusation No 4775 was filed before the Board of Pharmacy (Board) Department

of Consumer Affairs and is cunently pending against Respondent Chung The Accusation and

all other statutorily required documents were properly served on Respondent Chung on April 4

2014 Respondent Chung timely filed her Notice of Defense contesting the Accusation

6 A copy _of Accusation No 4775 is attached as exhibit A and incorporated herein by

reference

ADVISEMENT AND WAIVERS

7 Respondent Chung has carefully read fully discussed with counsel and understands

the charges and allegations in Accusation No 4775 Respondent Chung has also carefully read

fully discussed withcounsel and understands the effects of this Stipulated Settlement and

Disciplinary Order

8 Respondent Chung is fully aware of her legal rights in this matter including the right

to a hearing on the charges and allegations in the Accusation the right to be represented by

counsel at her own expense the right to confront and cross-examine the witnesses against her the

right to present evidence and to testify on her own behalf the right to the issuance of subpoenas

to compel the attendance of witnesses and the production of documents the right to

2

STIPULATED SETTLEMENT (4775)

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reconsideration and court review of an adverse decision and all other rights accorded by the

California Administrative Procedure Act and other applicable laws

9 Respondent Chtmg voluntarily knowingly and intelligently waives and gives up each

and every right set forth above

CULPABILITY

10 Respondent Chung understands and agrees that the charges and allegations in

Accusation No 4 775 if proven at a hearing constitute cause for imposing discipline upon her

Original PhaJmacy License

11 For the purpose of resolving the Accusation without the expense and uncertainty of

further proceedings Respondent Chung agrees that at a hearing Complainant could establish a

factual basis for the charges in the Accusation and that Respondent Chung hereby gives up her

right to contest those charges

-12 Respondent Chung agrees that her Original Pharmacist License is subject to

discipline and she agrees to be bound by the Boards probationary terms as set forth in the

Disciplinary Order below

CONTINGENCY

13 This stipulation shall be subject to approval by the Board of Pharmacy Respondent

Chung understands and agrees that counsel for Complainant and the staff of the Board of

Pharmacy may communicate directly with the Hoard regarding this stipulation and settlement

without notice to or participation by Respondent Chung or her counsel By signing the

stipulation Respondent Chung understands and agrees that she may not withdraw her agreement

or seek to rescind the stipulation pri01to the time the Board considers and acts upon it If the

Board fails to adopt this stipulation as its Decision and Order the Stipulated Settlement and

Disciplinary Order shall be of no force or effect except for this paragraph it shall be inadmissiblemiddot

in any legal action between the parties and the Board shall not be disqualified from further action

by having considered this matter

STIPULATED SETTLEMENT (4775)

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14 The parties understand and agree that Portable middotDocument Format (PDF) and facsimile - middot _ - bull --

copies of this Stipulated Settlement and Disciplinary Order including Portable Document Format

(PDF) and facsimile signatures thereto shall have the same force and effeCt as the originals

15 This Stipulated Settlement and Disciplinary Order is intended by the parties to bean

integrated writing representing the complete final and exclusive embodiment of their agreement

It supersedes any and all prior or contemporaneous agreements understandings discussions

negotiations and commitments (written or oral) This Stipulated Settlement and Disciplinary

Order may not be altered amended modified supplemented or middototherwise changed except by a

writing executed by an authorized representative of each of the parties

16 In consideration of the foregoing admissions and stipulations the parties agree that

the Board may without fmiher notice or formal proceeding issue and enter the following

Disciplinary Order

DISCIPLINARY ORDER

IT IS HEREBY ORDERED that Original Pharmacist License No RPH 40932 issued to

Respondent Anne Chon-Yin Chung (Respondent Chung) is revoked However the revocation is

stayed and Respondent Chung is placed on probation for five (5) years on the following terms and

conditions

1 Suspension

As part of probation Respondent Chung is suspended from the practice of pharmacy for

pinety (20_) dyS beginni-g tlJ~ effective dateCf~~is 4ecis~on

During suspension Respondent Chung shall not enter any pharmacy area or any portion of

the licensed premises of a wholesaler veterinary food-animal drug retailer or any other distributor

of drugs which is licensed by the board or any manufacturer or where dangerous drugs and

devices or controlled substances are maintained Respondent Chung shall not practice pharmacy

nor do any act involving drug selection selection of stock manufacturing compounding

dispensing or patient consultation nor shall Respondent Chung 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 and devices or controlled substances

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STIPULATED SETTLEMENT ( 4 775)

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Respondent Chung shall not engage in any activity that requires the professionll judgment bullbull middotmiddotmiddotmiddotbull -~middotmiddotmiddot bull middotbullbull bull bull bull bull bull bull bull bull bull -middot bull - bull middot-middot bull bull bull bull

of a pharmacist Respondent Chung shall not direct or control any aspect of the practice of

phannacy Respondent Chung shall not perform the duties of a pharmacy technician or a

designated representative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in aliy licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwise speCified in this order

Failure to comply with this suspension shall be considered a violation of probation

2 Obey All Laws

Respondent Chung shall obey all state and federal laws and regulations

Respondent Chung shall report any of the following occurrences to the board in writing

within seventy-two (72) hours of such occunence

bull an anest or issuance of a criminal complaint for violation of any provision of the

Pharmacy Law state and federal food and drug laws or state and federal controlled

substances laws

bull a plea of guilty or nolo contendre in any state or federal criminal proceeding to any

criminal complaint information or indictment

bull a conviction of any crime

discipline citation or other administrative action filed by any state or federal agency

which involves Respondent Chungs Pharmacist License or which is related to the

practice of pharmacy or the manufacturing obtaining handling distributing billing

or charging for any drug device or controlled substance

Failure to timely report such occurrence shall be considered middota violation of probation

3 Report to the Board

Respondent Chung shall ryport to the board quarterly on a schedule as directed by the

board or its designee The report shall be made either in person or in writing as directed Among

other requirements Respondent Chung shall state in each report under penalty of perjury whether

there has been compliance with all the terms and conditions of probation Failure to submit

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STIPULATED SETTLEMENT (4775)

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_fmely reports in a f~rrn a~ directed shall be considered a violation ofprobation Any period(s) of middot- bull middotmiddotmiddot-middot middot- middot middot-

delinquency in submission of reports as directed may be added to the total period of probation

Moreover if the final probation report is not made as directed probation shall be automatically

extended w1til such time as the final report is made and accepted by the board

4 Interview with the Board

Upon receipt of reasonable prior notice Respondent Chung shall appear in person for

interviews with the board or its designee at such intervals and locations as are determined by the

board or its designee Failure to appear for any scheduled interview without prior notification to

board staff or failure to appear for two (2) or more scheduled interviews with the board or its

designee during the period of probation shall be considered a violation of probation

5 Cooperate with Board Staff

Respondent Chung shall cooperate with the boards inspection program and with the boards

monitoring and investigation of Respondent Chungs compliance with the terms and conditions of

her probation Failure to cooperate shall be considered a violation of probation

6 Continuing Education

Respondent Chung shall provide evidence of efforts to maintain skill and knowledge as a

pharmacist as directed by the board or its designee

7 Notice to Employers

During the period of probation Respondent Chung shall notify all present and prospective

employers of the decision in case number 4775 and the terms conditions and restrictions imposed

on Respondent Chung by the decision as follows

Within thirty (30) days ofthe effective date ofthis decision and within fifteen (15) days of

Respondent Chtmg undertaking any new employment Respondent Chung shall cause her direct

supervisor pharmacist-in-charge (including each new pharmacist-in-charge employed during

Respondent Chung s tenure of employment) and owner to report to the board in writing

acknowledging that the listed individual(s) hashave read the decision in case number 4775 and

terms and conditions imposed thereby It shall be Respondent Chungs responsibility to ensure

that her employer(s) andor supervisor(s) submit timely acknowledgment(s) to the board

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STIPULATED SETTLEMENT (4775) I

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-~

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-middot~-Jf)3~e_spo_rA~ntChl1ng V~rlcs for_or is ~mploye~ b)or tlyough (l Jh~JEaCY eJ11ployment

service Respondent Chung must notify her direct supervisor phannacist-in-charge and owner at

every entity ~icensed by the board of the terms arid conditions of the decision in case number

4775 in advance of the Respondent Chung commencing work at each licensed entity A record of

this notification mustbe provided to the board upon request

Furthemore within thiliy (30) days ofthe effective date of this decision and within fifteen

(15) days of Respondent Chung undertaking any Hew employment by or through a pharmacy

employment service Respondent Chlmg shall cause her direct supervisor with the pharmacy

employment service to report to the board in writing acknowledging that she has read the decision

in case number 4775 and the terms and conditions imposed thereby It shall be Respondent

Chlings respmisibility to ensure that her employer(s) andor supervisor(s) submit timely

acknowledgment(s) to the board

Failure to timely notify present or prospective employer(s) or to cause thatthose

employer(s) to submit timely acknowledgments to the board shall be considered a violation of

probation

Employment within the meaning of this provision shall include any full-time

pali-time temporary relief or pharmacy management service as a pharmacist or any

position for which a pharmacist license is a requirement or criterion for employment

whether the Respondent Chung is an employee independent contractor or volunteer

8 No Supervision oflnterns Serving as Pharmacist-in-Charge (PIC) Serving as Designated Representative-in-Charge or Serving as a Consultant

During the period of probation R~spondent Chlmg shall not supervise any intern

pharmacist be the pharmacist-in-charge or designated representative-in-charge of any entity

licensed by the board nor serve as a consultant unless otherwise specified in this order

Assumption of any such unauthorized supervision responsibilities shall middotbe considered a violation

of probation

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9 Reimbursement of Board Costs

As a condition precedent to successful completion of probation Respondent Chung shall

pay to the board its costs of investigation and prosecution in the amount of $826533

Respondent Chung shall make said payment on a payment plan approved by the board

There shall be no deviation from this schedule absent prior written middotapproval by the board or

its designee Failure to pay costs by the deadline(s) as directed shall be considered a violation of

probation

The filing of bankruptcy by Respondent Chung shall not relieve Respondent Chung of her

responsibility to reimburse the board its costs of investigation and prosecution

10 Probation Monitoring Costs

Respondent Chung shall pay any costs associated with probation monitoring as determined

by the board each and every year of probation Such costs shall be payable to the board on a

schedule as directed by the board or its designee Failure to pay such costs by the deadline(s) as

directed shall be considered a violation of probation

11 Status of License

Respondent Chung shall at all times while on probation maintain an active current license

with the boaid including any period during which suspension or probation is tolled Failure to

maintain an active current license shall be considered a violation of probation

IfRespondent ChLmg1s license expires or is cancelled by operation of law or otherwise at

any time during the period of probation including any extensions thereof due to tolling or

otherwise upon renewal or reapplication Respondent Chung1s license shall be subject to all terms

and conditions of this probation not previously satisfied

12 License Surrender While on ProbationSuspension

Following the effective date of this decision should Respondent Chung cease practice due

to retirement or health or be otherwise unable to satisfy the terms and conditions ofprobatiori

Respondent Chung maytender her license to the board for surrender The board or its designee

shall have the discretion whether to grant the request for surrender or take any other action it

deems appropriate and reasonable Upon formal acceptance of the surrender of the license

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STIPULATED SETTLEMENT ( 4 775)

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~~~E~-~d~n~__ ghu~will P-0 lltn~er be subject to ~e ~rrns an~ cndii_ol~ ofpro~a~ion This

surrender constitutes a record of discipline and shall become a part of the Respondent Chungs

license history with the board

Upon acceptance of the surrender Respondent Chung shall relinquish her pocket and wall

license to the board within ten ( 1 0) middotdays of notification by the board that the surrender is

accepted Respondent Chung may not reapply for any license from the board for three (3) years

from the effective date of the surrender Respondent Chung shall meet all requirements

applicable to the license sought as of the date the application for that license is submitted to the

board including any outstanding costs

13 Notification of a Change in N arne Residence Address Mailing Address or Employment middot

Respondent Chung shall notify the hoard in writing within ten (10) days of any change of

employment Said notification shall include the reasons for leaving the address of the new

~mployer the name ofthe supervise and owner and the work schedule ifknown Respondent

Chung shall further notify the board in writing within ten (1 0) days of a change in name

residence address mailing address or phone number

Failure to timely notify the board of any change in employer(s) name(s) address(es) or

phone number( s) shall be considered a violation of probation

14 Tolling of Probation

Except during periods of suspension Respondent Chung shall at all times while on

probation be employed as a pharmacist in California for a minimum of 40 hours per calendar

month Any month during which this minimum is not met shall toll the period of probation ie

the period ofpimiddotobation shall be extended by one month for each month during which this

minimum is not met During any such period oftolling of probation Respondent Chung must

nonetheless comply with all terms and conditions of probation

Should Respondent Chung regardless of residency for any reason (including vacation)

cease practicing as a pharmacist for a minimum of 40 hours per calendar month in California

Respondent Chung must notify the board in writing within ten (1 0) days of the cessation of

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STIPULATED SETTLEMENT ( 4775)

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practice and must further notify the board in writing within ten (1 0) days of the resumption of middotmiddot-middot -~ __ -- middot---middot- ~--

practice Any failure to provide such notification(s) shall be considered a violation of probation

It is a violation ofprobation for Respondent Chung1s probation to remain tolled pursuant to

the provisions of this condition for a total period counting consecutive and non-consecutive

months exceeding thirty-six (36) months

Cessation of practice means any cale~dar month during which Respondent

Chung is not practicing as a pharmacist for at least 40 hours as defined by Business

and Professions Code section 4000 et seq Resumption of practice means any

calendar month during which Respondent Chung is practicing as a pharmacist for at

least 40 hours as a pharmacist as defined by Business and Professions Code section

4000 et seq

15 Violation of Probation

If a Respondent Chung has not complied with any term or condition of probation the board

shall have continuing jurisdiction over Respondent Chung and probation shall automatically be

extended until all terms and conditions have been satisfied 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 that was stayed

If Respondent Chung violates probation in any respect the board after giving Respondent

Chung notice and an opportunity to be heard may revoke probation and carry out the disciplinary

order that was stayed Notice and opportunity to be heard are not required for those provisions

stating that a violation thereof may lead to automatic termination of the stay andor revocation of

the license If a petition to revoke probation or an accusation is filed against Respondent Chung

during probation the board shall have continuing jurisdiction and the period of probation shall be

automatically extended until the petition to revoke probation or accusation is heard and decided

16 Completion ofProbation

Upon written notice by the board or its designee indicating successful completion of

probation Respondent Chungs license will be fully restored

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STIPULATED SETTLEMENT (4775)

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17 Community Services Program middotmiddot--middot bull bullbull-bull _H_ bullI bull bullmiddotmiddotmiddotmiddotmiddot-~ bullmiddotbullbullo-middot bull bull~--middotmiddot-~---middotbull-bull~--bull-bullgtmiddotmiddot middotmiddotmiddotgtbull-bullmiddotbull -

Vilithin sixty (60) days of the effective date of this decision Respondent Chung shall submit

to the board or its designee for prior approval a community service program in which

Respondent Chung shall provide free health-care related services on a regular basis to a

middot

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community or charitable facility or agency foimiddot at least 64 hours per year for each year of

probation Within thirty (30) days ofboard approval thereof Respondent Chung shall submit

documentation to the board demonstrating commencement of the community service program A

record ofthis notification must be provided to the board upon request Respondent Chung shall

report on progress with the community service program in the quarterly reports Failure to timely

submit con1inenceor comply witi1 the program shall be considered a violation of probation

18 Remedial Education

Yfithin sixty (60) days of the effective date ofthis decision Respondent Chung shall submit

to the board or its designee for prior approval an appropriate program of remedial education

related to dispensing of controlled substances corresponding responsibility and appropriate

controlled substance therapy The program of remedial education shall consist of at least ten (1 0)

units which shall be completed within the first three years of probation at Respondent Chung1s

own expense All remedial education shall be in addition to and shall not be credited toward

continuing education (CE) courses used for license renewal purposes

Failure to timely submit or complete the approved remedial education shall be considered a

violation of probation The period of probation will be automatically extended until such

remedial education is successfully completed and writte1i proof in a form acceptable to the board

is provided to the board or its designee

Following the completion of each course the board or its designee may require the

Respondent Chung at her own expense to take an approved examination to test the Respondent

Chung1s knowledge of the course If the Respondent Chung does not achieve a passing score on

the examination this failure shall be considered a violation ofprobation Any such examination

failure shall require Respondent Chung to take another course approved by the board in the same

subject area

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STIPULATED SETTLEMENT (4775) I

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19 Supervised Practi(e

During the period of probation Respondent Chung shall practice only under the supervision

of a licens~d pharmacist not on probation with the board Upon and after the effective date of this

decision Respondent Chung shall not practice pharmacy and her license shall be automatically

suspended until a supervisor is approved by the board or its designee The supervision shall be

as required by the board or its designee either

Continuous- At least 75 of a work week

Substantial - At least 50 of a wotk week

Partial- At least 25 of a work week

Daily Review- Supervisor1s review of probationer1S daily activities within 24 hours

Within thirty (30) days ofthe effective date of this decision Respondent Chung shall have

her supervisor submit notification to the board in writing stating that the supervisor has read the

decision iri case number 4775 and is familiar with the required level of supervision as determined

by the board or its designee It shall be the Respondent Chungs responsibility to ensme that her

employer(s) pharmacist-in-charge andor supervisor(s) submit timely acknowledgement(s) to the

board Failure to cause the direct supervisor and the pharmacist-in-charge to submit timely

acla1owledgements to the board shall be considered a violation of probation

If Respondent Chung changes employment it shall be the Respondent Chung s

responsibility to ensure that her employer(s) pharmacist-in-charge andor supervisor(s) submit

timely acknowledgement(s) to the board Respondent Chung shall have her new supervisor

within fifteen (15) days after employment commences submit notification to the board in writing

stating the direct supervisor and pharmacist-in-charge have read the decision in case number 4775

and is familiar with the level of supervision as determined by the board Respondent Chung shall

not practice pharmacy and her license shall be automatically suspended until the board or its

designee approves a new supervisor Failure to cause the direct supervisor and the phannacist-inshy

charge to submit timely acknowledgements to the board shall be considered a violation of

probation

Within ten (1 0) days of leaving employment Respondent Chung shall notify the board in

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writing

During suspension Respondent Chung shall not enter any pharmacy area or any portion of

the licensed premises of a wholesaler veterinary food-animal drug retailer or any other distributor

of drugs which is licensed by the board or any manufacturer or where dangerous drugs and

devices or controlled substances are maintained Respondent ChtmgBhallmiddotnotpractice pharmacy

nor do any act involving drug selection selection of stock manufacturing compounding

dispensing or patient consultation nor shall Respondent Chung 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 and controlled substances Respondent Chung shall not resume

practice until notified by the board

During suspension Respondent Chung shall not engage in any activity that requires the

professional judgment of a pharmacist Respondent Chung shall not direct or control any aspect

of the practice of pharmacy Respondent Chung shall not perform the duties of a pharmacy

technician or a designatedrepresentative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in arty licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwisespecified in thismiddot order

Failure to comply with this suspension shall be considered a violation of probation

20 No Ownership of Licensed Premises

Respondent Chung shall not own have any legal or beneficial interest in or serve as a

manager administrator member officer director trustee associate or partner of any business

firm pruinership or corporation currently or hereinafter licensed by the board Respondent

Chung shall sell or transfer any legal or beneficial interest in any entity licensed by the board

within ninety (90) days followiiig the effective date of this decision and shallimmediately

thereafter provide written proof thereof to the borumiddotd Failure to timely divest any legal or

beneficial interest(s) or provide documentation thereof shall be considered a violation of

probation

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STIPULATED SETTLEMENT (4775) I

r-----------------------------------------middot-middotmiddotmiddot-middotmiddot -

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21 Tolling of Suspension

During the period of suspension respondent shall not leave California for any period

exceeding ten (10) days regardless of purpose (including vacation) Any such absence in excess

ofthe (10) days d11ring suspension shall be considered a violation of probation Moreover any

absence from California during the period of suspension exceeding ten (1 0) days shall toll the

suspension ie the suspension shall be extended by one day for each day over ten (10) days

respondent is absent from California During any such period of tolling of suspension respondent

must nonetheless comply with all terms m1d conditions of probation

Respondent must notify the bomd in writing within ten (1 0) days of departure and must

further notify the board in writing within ten (1 0) days of return The f~ilure to provide such

notification(s) shall constitute a violation ofprobation Upon such departure m1d return

respondent shall not resume the practice ofpharmacy until notified by the board that the period of

middotsuspension has been satisfactorily completed

ACCEPTANCE

I have carefully read the above Stipulated Settlement and Disciplinary Order and have fully

discussed it with my attorney Benjamin Robert Margolis I understm1d the stipulation m1d the

effect it will have on my Original Pharmacist License I enter into this Stipulated Settlement and

Disciplinary Order voluntarily knowingly and intelligently and agree to be bound by the

Decision and Order of the Bommiddotd of Pharmacy

DATED I Anne Chon-Yin Chun ka A1me Chung

of

I have read m1d fully discussed with Respondent Chung the terms and conditions and other

matters contained in the above Stipulated2ettlet and Disciplinary Or~~middot~r__approve its form

and content middot ---~ -shy

DATED joj j1y ~ ~~middot-- bull J J~nj airul1Kobert Margolis

Lttorney for Respondent Chung

14 STIPULATED SETTLEMENT (4775)

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ENDORSEMENT

The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully

submitted for consideration by the Board of Pharmacy

Dated D -I - ~ Respectfully submitted

KAMALA D HARRIS Attorney General of California MARC D GREENBAUM Supervising Deputy Atton1ey General

GILLIAN E FRIEDMAN Deputy Attorney General Attorneys for Complainant

LA2013509837 51608369doc

15

STIPULATED SETTLEMENT (4775)

Exhibit A

Accusation No 4775

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KAMALA D HARRlS A ttomey General of California MARC D GREENBAUM SuperVisingDeputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207 middot 300 So Spring Street Suite 1702

Los Angeles CA 90013 Telephone (213)897-2564 Facsimile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OF PHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Again~t

RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 PharmacyPermit No PHY 42331

ANNE CHON-YIN CHUNG 3 782 Moore Street Los Angeles CA 90066 Original Pharmacist License No RPH 40932

Respondents

Case No 4775

ACCUSATION

Complainant alleges

PARTIEsmiddot

1 Virginia Herold (Complainant) brings this Accusation solely in her official capacity

as the Executive Officer ofthe Board ofPharmacyDepartment of Consumer Affa)rs

2 On or about February 21 1997 the Board of Pharmacy issued Pharmacy Permit

Number PHY 42331 to Rite Aid 5429 located at 500 S Broadway Los Angeles California

90013-2302 (Respondent Rite Aid Pharmacy) The Pharmacy Permit was in full force and effect

Accusation

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at all times relevant to the charges brought herein and will expire on April 1 2014 unless

renewed

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932to Anne Chon-Yin Chu11g aka Anne Chung (Respondent Chung) The

Original Pharmacy License was in full force and effect at all times relevant to the charges brought

herein and will expire on January 312015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Respondent Rite Aiel Pharmacy

JURISDICTION

5 This Accusation is brought before the Board ofPharmacy (Board) Department of

Consumer Affairs under the authority onhe following laws All section references are to the

Business and Professions Code unless otherwise indicated

6 Section 4300 ofthe Code states

(a) Every license issued may be suspended or revoked

7 Section 4301 ofthe Code states

The board shall take action against any holder of a license who is guilty of unprofessional

conduct or whose license has been procured byfraud or misrepresentation or issued by mistake

Unprofessional conduct shall include but is not limited to any of the following

(a) Gross immorality

(b) Incompetence

(c) Gross negligence

(d) The clearly excessive furnishing of controiled substances in violation of subdivision (a)

of Section 11153 of the Health and Safety Code

(e) The cearly ~xces~iye furnishing of controlled substances in viqlation of subdivisiol (a)

of Section 111535 of the Health and Safety Code Factors to be considered in determining

whether the furnishing of controlled substances is clearly excessive shall include but not be

limited to the amount of controlled substances furnished the previous ordering pattern of the

2

Accusation

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customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

3

Accusation

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

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21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

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Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

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a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

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Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

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supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

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r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

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1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

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e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

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e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

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s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

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13

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19

21

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23

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middot26

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28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

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6

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9

II

12

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18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

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28

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

5

10

15

20

25

2

3

4

6

7

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13

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17

18

19

21

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23

24

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28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

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23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

2

3

4

5

6

7

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9

10

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

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I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

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f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

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e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

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4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

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reconsideration and court review of an adverse decision and all other rights accorded by the

California Administrative Procedure Act and other applicable laws

9 Respondent Chtmg voluntarily knowingly and intelligently waives and gives up each

and every right set forth above

CULPABILITY

10 Respondent Chung understands and agrees that the charges and allegations in

Accusation No 4 775 if proven at a hearing constitute cause for imposing discipline upon her

Original PhaJmacy License

11 For the purpose of resolving the Accusation without the expense and uncertainty of

further proceedings Respondent Chung agrees that at a hearing Complainant could establish a

factual basis for the charges in the Accusation and that Respondent Chung hereby gives up her

right to contest those charges

-12 Respondent Chung agrees that her Original Pharmacist License is subject to

discipline and she agrees to be bound by the Boards probationary terms as set forth in the

Disciplinary Order below

CONTINGENCY

13 This stipulation shall be subject to approval by the Board of Pharmacy Respondent

Chung understands and agrees that counsel for Complainant and the staff of the Board of

Pharmacy may communicate directly with the Hoard regarding this stipulation and settlement

without notice to or participation by Respondent Chung or her counsel By signing the

stipulation Respondent Chung understands and agrees that she may not withdraw her agreement

or seek to rescind the stipulation pri01to the time the Board considers and acts upon it If the

Board fails to adopt this stipulation as its Decision and Order the Stipulated Settlement and

Disciplinary Order shall be of no force or effect except for this paragraph it shall be inadmissiblemiddot

in any legal action between the parties and the Board shall not be disqualified from further action

by having considered this matter

STIPULATED SETTLEMENT (4775)

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14 The parties understand and agree that Portable middotDocument Format (PDF) and facsimile - middot _ - bull --

copies of this Stipulated Settlement and Disciplinary Order including Portable Document Format

(PDF) and facsimile signatures thereto shall have the same force and effeCt as the originals

15 This Stipulated Settlement and Disciplinary Order is intended by the parties to bean

integrated writing representing the complete final and exclusive embodiment of their agreement

It supersedes any and all prior or contemporaneous agreements understandings discussions

negotiations and commitments (written or oral) This Stipulated Settlement and Disciplinary

Order may not be altered amended modified supplemented or middototherwise changed except by a

writing executed by an authorized representative of each of the parties

16 In consideration of the foregoing admissions and stipulations the parties agree that

the Board may without fmiher notice or formal proceeding issue and enter the following

Disciplinary Order

DISCIPLINARY ORDER

IT IS HEREBY ORDERED that Original Pharmacist License No RPH 40932 issued to

Respondent Anne Chon-Yin Chung (Respondent Chung) is revoked However the revocation is

stayed and Respondent Chung is placed on probation for five (5) years on the following terms and

conditions

1 Suspension

As part of probation Respondent Chung is suspended from the practice of pharmacy for

pinety (20_) dyS beginni-g tlJ~ effective dateCf~~is 4ecis~on

During suspension Respondent Chung shall not enter any pharmacy area or any portion of

the licensed premises of a wholesaler veterinary food-animal drug retailer or any other distributor

of drugs which is licensed by the board or any manufacturer or where dangerous drugs and

devices or controlled substances are maintained Respondent Chung shall not practice pharmacy

nor do any act involving drug selection selection of stock manufacturing compounding

dispensing or patient consultation nor shall Respondent Chung 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 and devices or controlled substances

4

STIPULATED SETTLEMENT ( 4 775)

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Respondent Chung shall not engage in any activity that requires the professionll judgment bullbull middotmiddotmiddotmiddotbull -~middotmiddotmiddot bull middotbullbull bull bull bull bull bull bull bull bull bull -middot bull - bull middot-middot bull bull bull bull

of a pharmacist Respondent Chung shall not direct or control any aspect of the practice of

phannacy Respondent Chung shall not perform the duties of a pharmacy technician or a

designated representative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in aliy licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwise speCified in this order

Failure to comply with this suspension shall be considered a violation of probation

2 Obey All Laws

Respondent Chung shall obey all state and federal laws and regulations

Respondent Chung shall report any of the following occurrences to the board in writing

within seventy-two (72) hours of such occunence

bull an anest or issuance of a criminal complaint for violation of any provision of the

Pharmacy Law state and federal food and drug laws or state and federal controlled

substances laws

bull a plea of guilty or nolo contendre in any state or federal criminal proceeding to any

criminal complaint information or indictment

bull a conviction of any crime

discipline citation or other administrative action filed by any state or federal agency

which involves Respondent Chungs Pharmacist License or which is related to the

practice of pharmacy or the manufacturing obtaining handling distributing billing

or charging for any drug device or controlled substance

Failure to timely report such occurrence shall be considered middota violation of probation

3 Report to the Board

Respondent Chung shall ryport to the board quarterly on a schedule as directed by the

board or its designee The report shall be made either in person or in writing as directed Among

other requirements Respondent Chung shall state in each report under penalty of perjury whether

there has been compliance with all the terms and conditions of probation Failure to submit

5

STIPULATED SETTLEMENT (4775)

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_fmely reports in a f~rrn a~ directed shall be considered a violation ofprobation Any period(s) of middot- bull middotmiddotmiddot-middot middot- middot middot-

delinquency in submission of reports as directed may be added to the total period of probation

Moreover if the final probation report is not made as directed probation shall be automatically

extended w1til such time as the final report is made and accepted by the board

4 Interview with the Board

Upon receipt of reasonable prior notice Respondent Chung shall appear in person for

interviews with the board or its designee at such intervals and locations as are determined by the

board or its designee Failure to appear for any scheduled interview without prior notification to

board staff or failure to appear for two (2) or more scheduled interviews with the board or its

designee during the period of probation shall be considered a violation of probation

5 Cooperate with Board Staff

Respondent Chung shall cooperate with the boards inspection program and with the boards

monitoring and investigation of Respondent Chungs compliance with the terms and conditions of

her probation Failure to cooperate shall be considered a violation of probation

6 Continuing Education

Respondent Chung shall provide evidence of efforts to maintain skill and knowledge as a

pharmacist as directed by the board or its designee

7 Notice to Employers

During the period of probation Respondent Chung shall notify all present and prospective

employers of the decision in case number 4775 and the terms conditions and restrictions imposed

on Respondent Chung by the decision as follows

Within thirty (30) days ofthe effective date ofthis decision and within fifteen (15) days of

Respondent Chtmg undertaking any new employment Respondent Chung shall cause her direct

supervisor pharmacist-in-charge (including each new pharmacist-in-charge employed during

Respondent Chung s tenure of employment) and owner to report to the board in writing

acknowledging that the listed individual(s) hashave read the decision in case number 4775 and

terms and conditions imposed thereby It shall be Respondent Chungs responsibility to ensure

that her employer(s) andor supervisor(s) submit timely acknowledgment(s) to the board

6

STIPULATED SETTLEMENT (4775) I

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-~

Ill

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-middot~-Jf)3~e_spo_rA~ntChl1ng V~rlcs for_or is ~mploye~ b)or tlyough (l Jh~JEaCY eJ11ployment

service Respondent Chung must notify her direct supervisor phannacist-in-charge and owner at

every entity ~icensed by the board of the terms arid conditions of the decision in case number

4775 in advance of the Respondent Chung commencing work at each licensed entity A record of

this notification mustbe provided to the board upon request

Furthemore within thiliy (30) days ofthe effective date of this decision and within fifteen

(15) days of Respondent Chung undertaking any Hew employment by or through a pharmacy

employment service Respondent Chlmg shall cause her direct supervisor with the pharmacy

employment service to report to the board in writing acknowledging that she has read the decision

in case number 4775 and the terms and conditions imposed thereby It shall be Respondent

Chlings respmisibility to ensure that her employer(s) andor supervisor(s) submit timely

acknowledgment(s) to the board

Failure to timely notify present or prospective employer(s) or to cause thatthose

employer(s) to submit timely acknowledgments to the board shall be considered a violation of

probation

Employment within the meaning of this provision shall include any full-time

pali-time temporary relief or pharmacy management service as a pharmacist or any

position for which a pharmacist license is a requirement or criterion for employment

whether the Respondent Chung is an employee independent contractor or volunteer

8 No Supervision oflnterns Serving as Pharmacist-in-Charge (PIC) Serving as Designated Representative-in-Charge or Serving as a Consultant

During the period of probation R~spondent Chlmg shall not supervise any intern

pharmacist be the pharmacist-in-charge or designated representative-in-charge of any entity

licensed by the board nor serve as a consultant unless otherwise specified in this order

Assumption of any such unauthorized supervision responsibilities shall middotbe considered a violation

of probation

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9 Reimbursement of Board Costs

As a condition precedent to successful completion of probation Respondent Chung shall

pay to the board its costs of investigation and prosecution in the amount of $826533

Respondent Chung shall make said payment on a payment plan approved by the board

There shall be no deviation from this schedule absent prior written middotapproval by the board or

its designee Failure to pay costs by the deadline(s) as directed shall be considered a violation of

probation

The filing of bankruptcy by Respondent Chung shall not relieve Respondent Chung of her

responsibility to reimburse the board its costs of investigation and prosecution

10 Probation Monitoring Costs

Respondent Chung shall pay any costs associated with probation monitoring as determined

by the board each and every year of probation Such costs shall be payable to the board on a

schedule as directed by the board or its designee Failure to pay such costs by the deadline(s) as

directed shall be considered a violation of probation

11 Status of License

Respondent Chung shall at all times while on probation maintain an active current license

with the boaid including any period during which suspension or probation is tolled Failure to

maintain an active current license shall be considered a violation of probation

IfRespondent ChLmg1s license expires or is cancelled by operation of law or otherwise at

any time during the period of probation including any extensions thereof due to tolling or

otherwise upon renewal or reapplication Respondent Chung1s license shall be subject to all terms

and conditions of this probation not previously satisfied

12 License Surrender While on ProbationSuspension

Following the effective date of this decision should Respondent Chung cease practice due

to retirement or health or be otherwise unable to satisfy the terms and conditions ofprobatiori

Respondent Chung maytender her license to the board for surrender The board or its designee

shall have the discretion whether to grant the request for surrender or take any other action it

deems appropriate and reasonable Upon formal acceptance of the surrender of the license

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~~~E~-~d~n~__ ghu~will P-0 lltn~er be subject to ~e ~rrns an~ cndii_ol~ ofpro~a~ion This

surrender constitutes a record of discipline and shall become a part of the Respondent Chungs

license history with the board

Upon acceptance of the surrender Respondent Chung shall relinquish her pocket and wall

license to the board within ten ( 1 0) middotdays of notification by the board that the surrender is

accepted Respondent Chung may not reapply for any license from the board for three (3) years

from the effective date of the surrender Respondent Chung shall meet all requirements

applicable to the license sought as of the date the application for that license is submitted to the

board including any outstanding costs

13 Notification of a Change in N arne Residence Address Mailing Address or Employment middot

Respondent Chung shall notify the hoard in writing within ten (10) days of any change of

employment Said notification shall include the reasons for leaving the address of the new

~mployer the name ofthe supervise and owner and the work schedule ifknown Respondent

Chung shall further notify the board in writing within ten (1 0) days of a change in name

residence address mailing address or phone number

Failure to timely notify the board of any change in employer(s) name(s) address(es) or

phone number( s) shall be considered a violation of probation

14 Tolling of Probation

Except during periods of suspension Respondent Chung shall at all times while on

probation be employed as a pharmacist in California for a minimum of 40 hours per calendar

month Any month during which this minimum is not met shall toll the period of probation ie

the period ofpimiddotobation shall be extended by one month for each month during which this

minimum is not met During any such period oftolling of probation Respondent Chung must

nonetheless comply with all terms and conditions of probation

Should Respondent Chung regardless of residency for any reason (including vacation)

cease practicing as a pharmacist for a minimum of 40 hours per calendar month in California

Respondent Chung must notify the board in writing within ten (1 0) days of the cessation of

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practice and must further notify the board in writing within ten (1 0) days of the resumption of middotmiddot-middot -~ __ -- middot---middot- ~--

practice Any failure to provide such notification(s) shall be considered a violation of probation

It is a violation ofprobation for Respondent Chung1s probation to remain tolled pursuant to

the provisions of this condition for a total period counting consecutive and non-consecutive

months exceeding thirty-six (36) months

Cessation of practice means any cale~dar month during which Respondent

Chung is not practicing as a pharmacist for at least 40 hours as defined by Business

and Professions Code section 4000 et seq Resumption of practice means any

calendar month during which Respondent Chung is practicing as a pharmacist for at

least 40 hours as a pharmacist as defined by Business and Professions Code section

4000 et seq

15 Violation of Probation

If a Respondent Chung has not complied with any term or condition of probation the board

shall have continuing jurisdiction over Respondent Chung and probation shall automatically be

extended until all terms and conditions have been satisfied 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 that was stayed

If Respondent Chung violates probation in any respect the board after giving Respondent

Chung notice and an opportunity to be heard may revoke probation and carry out the disciplinary

order that was stayed Notice and opportunity to be heard are not required for those provisions

stating that a violation thereof may lead to automatic termination of the stay andor revocation of

the license If a petition to revoke probation or an accusation is filed against Respondent Chung

during probation the board shall have continuing jurisdiction and the period of probation shall be

automatically extended until the petition to revoke probation or accusation is heard and decided

16 Completion ofProbation

Upon written notice by the board or its designee indicating successful completion of

probation Respondent Chungs license will be fully restored

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STIPULATED SETTLEMENT (4775)

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17 Community Services Program middotmiddot--middot bull bullbull-bull _H_ bullI bull bullmiddotmiddotmiddotmiddotmiddot-~ bullmiddotbullbullo-middot bull bull~--middotmiddot-~---middotbull-bull~--bull-bullgtmiddotmiddot middotmiddotmiddotgtbull-bullmiddotbull -

Vilithin sixty (60) days of the effective date of this decision Respondent Chung shall submit

to the board or its designee for prior approval a community service program in which

Respondent Chung shall provide free health-care related services on a regular basis to a

middot

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community or charitable facility or agency foimiddot at least 64 hours per year for each year of

probation Within thirty (30) days ofboard approval thereof Respondent Chung shall submit

documentation to the board demonstrating commencement of the community service program A

record ofthis notification must be provided to the board upon request Respondent Chung shall

report on progress with the community service program in the quarterly reports Failure to timely

submit con1inenceor comply witi1 the program shall be considered a violation of probation

18 Remedial Education

Yfithin sixty (60) days of the effective date ofthis decision Respondent Chung shall submit

to the board or its designee for prior approval an appropriate program of remedial education

related to dispensing of controlled substances corresponding responsibility and appropriate

controlled substance therapy The program of remedial education shall consist of at least ten (1 0)

units which shall be completed within the first three years of probation at Respondent Chung1s

own expense All remedial education shall be in addition to and shall not be credited toward

continuing education (CE) courses used for license renewal purposes

Failure to timely submit or complete the approved remedial education shall be considered a

violation of probation The period of probation will be automatically extended until such

remedial education is successfully completed and writte1i proof in a form acceptable to the board

is provided to the board or its designee

Following the completion of each course the board or its designee may require the

Respondent Chung at her own expense to take an approved examination to test the Respondent

Chung1s knowledge of the course If the Respondent Chung does not achieve a passing score on

the examination this failure shall be considered a violation ofprobation Any such examination

failure shall require Respondent Chung to take another course approved by the board in the same

subject area

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STIPULATED SETTLEMENT (4775) I

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19 Supervised Practi(e

During the period of probation Respondent Chung shall practice only under the supervision

of a licens~d pharmacist not on probation with the board Upon and after the effective date of this

decision Respondent Chung shall not practice pharmacy and her license shall be automatically

suspended until a supervisor is approved by the board or its designee The supervision shall be

as required by the board or its designee either

Continuous- At least 75 of a work week

Substantial - At least 50 of a wotk week

Partial- At least 25 of a work week

Daily Review- Supervisor1s review of probationer1S daily activities within 24 hours

Within thirty (30) days ofthe effective date of this decision Respondent Chung shall have

her supervisor submit notification to the board in writing stating that the supervisor has read the

decision iri case number 4775 and is familiar with the required level of supervision as determined

by the board or its designee It shall be the Respondent Chungs responsibility to ensme that her

employer(s) pharmacist-in-charge andor supervisor(s) submit timely acknowledgement(s) to the

board Failure to cause the direct supervisor and the pharmacist-in-charge to submit timely

acla1owledgements to the board shall be considered a violation of probation

If Respondent Chung changes employment it shall be the Respondent Chung s

responsibility to ensure that her employer(s) pharmacist-in-charge andor supervisor(s) submit

timely acknowledgement(s) to the board Respondent Chung shall have her new supervisor

within fifteen (15) days after employment commences submit notification to the board in writing

stating the direct supervisor and pharmacist-in-charge have read the decision in case number 4775

and is familiar with the level of supervision as determined by the board Respondent Chung shall

not practice pharmacy and her license shall be automatically suspended until the board or its

designee approves a new supervisor Failure to cause the direct supervisor and the phannacist-inshy

charge to submit timely acknowledgements to the board shall be considered a violation of

probation

Within ten (1 0) days of leaving employment Respondent Chung shall notify the board in

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writing

During suspension Respondent Chung shall not enter any pharmacy area or any portion of

the licensed premises of a wholesaler veterinary food-animal drug retailer or any other distributor

of drugs which is licensed by the board or any manufacturer or where dangerous drugs and

devices or controlled substances are maintained Respondent ChtmgBhallmiddotnotpractice pharmacy

nor do any act involving drug selection selection of stock manufacturing compounding

dispensing or patient consultation nor shall Respondent Chung 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 and controlled substances Respondent Chung shall not resume

practice until notified by the board

During suspension Respondent Chung shall not engage in any activity that requires the

professional judgment of a pharmacist Respondent Chung shall not direct or control any aspect

of the practice of pharmacy Respondent Chung shall not perform the duties of a pharmacy

technician or a designatedrepresentative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in arty licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwisespecified in thismiddot order

Failure to comply with this suspension shall be considered a violation of probation

20 No Ownership of Licensed Premises

Respondent Chung shall not own have any legal or beneficial interest in or serve as a

manager administrator member officer director trustee associate or partner of any business

firm pruinership or corporation currently or hereinafter licensed by the board Respondent

Chung shall sell or transfer any legal or beneficial interest in any entity licensed by the board

within ninety (90) days followiiig the effective date of this decision and shallimmediately

thereafter provide written proof thereof to the borumiddotd Failure to timely divest any legal or

beneficial interest(s) or provide documentation thereof shall be considered a violation of

probation

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STIPULATED SETTLEMENT (4775) I

r-----------------------------------------middot-middotmiddotmiddot-middotmiddot -

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21 Tolling of Suspension

During the period of suspension respondent shall not leave California for any period

exceeding ten (10) days regardless of purpose (including vacation) Any such absence in excess

ofthe (10) days d11ring suspension shall be considered a violation of probation Moreover any

absence from California during the period of suspension exceeding ten (1 0) days shall toll the

suspension ie the suspension shall be extended by one day for each day over ten (10) days

respondent is absent from California During any such period of tolling of suspension respondent

must nonetheless comply with all terms m1d conditions of probation

Respondent must notify the bomd in writing within ten (1 0) days of departure and must

further notify the board in writing within ten (1 0) days of return The f~ilure to provide such

notification(s) shall constitute a violation ofprobation Upon such departure m1d return

respondent shall not resume the practice ofpharmacy until notified by the board that the period of

middotsuspension has been satisfactorily completed

ACCEPTANCE

I have carefully read the above Stipulated Settlement and Disciplinary Order and have fully

discussed it with my attorney Benjamin Robert Margolis I understm1d the stipulation m1d the

effect it will have on my Original Pharmacist License I enter into this Stipulated Settlement and

Disciplinary Order voluntarily knowingly and intelligently and agree to be bound by the

Decision and Order of the Bommiddotd of Pharmacy

DATED I Anne Chon-Yin Chun ka A1me Chung

of

I have read m1d fully discussed with Respondent Chung the terms and conditions and other

matters contained in the above Stipulated2ettlet and Disciplinary Or~~middot~r__approve its form

and content middot ---~ -shy

DATED joj j1y ~ ~~middot-- bull J J~nj airul1Kobert Margolis

Lttorney for Respondent Chung

14 STIPULATED SETTLEMENT (4775)

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ENDORSEMENT

The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully

submitted for consideration by the Board of Pharmacy

Dated D -I - ~ Respectfully submitted

KAMALA D HARRIS Attorney General of California MARC D GREENBAUM Supervising Deputy Atton1ey General

GILLIAN E FRIEDMAN Deputy Attorney General Attorneys for Complainant

LA2013509837 51608369doc

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STIPULATED SETTLEMENT (4775)

Exhibit A

Accusation No 4775

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KAMALA D HARRlS A ttomey General of California MARC D GREENBAUM SuperVisingDeputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207 middot 300 So Spring Street Suite 1702

Los Angeles CA 90013 Telephone (213)897-2564 Facsimile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OF PHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Again~t

RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 PharmacyPermit No PHY 42331

ANNE CHON-YIN CHUNG 3 782 Moore Street Los Angeles CA 90066 Original Pharmacist License No RPH 40932

Respondents

Case No 4775

ACCUSATION

Complainant alleges

PARTIEsmiddot

1 Virginia Herold (Complainant) brings this Accusation solely in her official capacity

as the Executive Officer ofthe Board ofPharmacyDepartment of Consumer Affa)rs

2 On or about February 21 1997 the Board of Pharmacy issued Pharmacy Permit

Number PHY 42331 to Rite Aid 5429 located at 500 S Broadway Los Angeles California

90013-2302 (Respondent Rite Aid Pharmacy) The Pharmacy Permit was in full force and effect

Accusation

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at all times relevant to the charges brought herein and will expire on April 1 2014 unless

renewed

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932to Anne Chon-Yin Chu11g aka Anne Chung (Respondent Chung) The

Original Pharmacy License was in full force and effect at all times relevant to the charges brought

herein and will expire on January 312015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Respondent Rite Aiel Pharmacy

JURISDICTION

5 This Accusation is brought before the Board ofPharmacy (Board) Department of

Consumer Affairs under the authority onhe following laws All section references are to the

Business and Professions Code unless otherwise indicated

6 Section 4300 ofthe Code states

(a) Every license issued may be suspended or revoked

7 Section 4301 ofthe Code states

The board shall take action against any holder of a license who is guilty of unprofessional

conduct or whose license has been procured byfraud or misrepresentation or issued by mistake

Unprofessional conduct shall include but is not limited to any of the following

(a) Gross immorality

(b) Incompetence

(c) Gross negligence

(d) The clearly excessive furnishing of controiled substances in violation of subdivision (a)

of Section 11153 of the Health and Safety Code

(e) The cearly ~xces~iye furnishing of controlled substances in viqlation of subdivisiol (a)

of Section 111535 of the Health and Safety Code Factors to be considered in determining

whether the furnishing of controlled substances is clearly excessive shall include but not be

limited to the amount of controlled substances furnished the previous ordering pattern of the

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Accusation

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customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

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Accusation

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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Accusation

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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Accusation

(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

7

Accusation I

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

8 Accusation

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middot

21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

10

Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

11

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Accusation

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a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

12

Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

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supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

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r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

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e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

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e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

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middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

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bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

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l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

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45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

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23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

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28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

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23

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25

26

27

28

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

3

4

5

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8

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I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

9

10

11

12

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25 I

26

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28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

2

3

4

5

6

7

8

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26

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

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Accusation

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

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Accusation

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

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Accusation

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e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

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4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

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14 The parties understand and agree that Portable middotDocument Format (PDF) and facsimile - middot _ - bull --

copies of this Stipulated Settlement and Disciplinary Order including Portable Document Format

(PDF) and facsimile signatures thereto shall have the same force and effeCt as the originals

15 This Stipulated Settlement and Disciplinary Order is intended by the parties to bean

integrated writing representing the complete final and exclusive embodiment of their agreement

It supersedes any and all prior or contemporaneous agreements understandings discussions

negotiations and commitments (written or oral) This Stipulated Settlement and Disciplinary

Order may not be altered amended modified supplemented or middototherwise changed except by a

writing executed by an authorized representative of each of the parties

16 In consideration of the foregoing admissions and stipulations the parties agree that

the Board may without fmiher notice or formal proceeding issue and enter the following

Disciplinary Order

DISCIPLINARY ORDER

IT IS HEREBY ORDERED that Original Pharmacist License No RPH 40932 issued to

Respondent Anne Chon-Yin Chung (Respondent Chung) is revoked However the revocation is

stayed and Respondent Chung is placed on probation for five (5) years on the following terms and

conditions

1 Suspension

As part of probation Respondent Chung is suspended from the practice of pharmacy for

pinety (20_) dyS beginni-g tlJ~ effective dateCf~~is 4ecis~on

During suspension Respondent Chung shall not enter any pharmacy area or any portion of

the licensed premises of a wholesaler veterinary food-animal drug retailer or any other distributor

of drugs which is licensed by the board or any manufacturer or where dangerous drugs and

devices or controlled substances are maintained Respondent Chung shall not practice pharmacy

nor do any act involving drug selection selection of stock manufacturing compounding

dispensing or patient consultation nor shall Respondent Chung 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 and devices or controlled substances

4

STIPULATED SETTLEMENT ( 4 775)

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Respondent Chung shall not engage in any activity that requires the professionll judgment bullbull middotmiddotmiddotmiddotbull -~middotmiddotmiddot bull middotbullbull bull bull bull bull bull bull bull bull bull -middot bull - bull middot-middot bull bull bull bull

of a pharmacist Respondent Chung shall not direct or control any aspect of the practice of

phannacy Respondent Chung shall not perform the duties of a pharmacy technician or a

designated representative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in aliy licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwise speCified in this order

Failure to comply with this suspension shall be considered a violation of probation

2 Obey All Laws

Respondent Chung shall obey all state and federal laws and regulations

Respondent Chung shall report any of the following occurrences to the board in writing

within seventy-two (72) hours of such occunence

bull an anest or issuance of a criminal complaint for violation of any provision of the

Pharmacy Law state and federal food and drug laws or state and federal controlled

substances laws

bull a plea of guilty or nolo contendre in any state or federal criminal proceeding to any

criminal complaint information or indictment

bull a conviction of any crime

discipline citation or other administrative action filed by any state or federal agency

which involves Respondent Chungs Pharmacist License or which is related to the

practice of pharmacy or the manufacturing obtaining handling distributing billing

or charging for any drug device or controlled substance

Failure to timely report such occurrence shall be considered middota violation of probation

3 Report to the Board

Respondent Chung shall ryport to the board quarterly on a schedule as directed by the

board or its designee The report shall be made either in person or in writing as directed Among

other requirements Respondent Chung shall state in each report under penalty of perjury whether

there has been compliance with all the terms and conditions of probation Failure to submit

5

STIPULATED SETTLEMENT (4775)

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_fmely reports in a f~rrn a~ directed shall be considered a violation ofprobation Any period(s) of middot- bull middotmiddotmiddot-middot middot- middot middot-

delinquency in submission of reports as directed may be added to the total period of probation

Moreover if the final probation report is not made as directed probation shall be automatically

extended w1til such time as the final report is made and accepted by the board

4 Interview with the Board

Upon receipt of reasonable prior notice Respondent Chung shall appear in person for

interviews with the board or its designee at such intervals and locations as are determined by the

board or its designee Failure to appear for any scheduled interview without prior notification to

board staff or failure to appear for two (2) or more scheduled interviews with the board or its

designee during the period of probation shall be considered a violation of probation

5 Cooperate with Board Staff

Respondent Chung shall cooperate with the boards inspection program and with the boards

monitoring and investigation of Respondent Chungs compliance with the terms and conditions of

her probation Failure to cooperate shall be considered a violation of probation

6 Continuing Education

Respondent Chung shall provide evidence of efforts to maintain skill and knowledge as a

pharmacist as directed by the board or its designee

7 Notice to Employers

During the period of probation Respondent Chung shall notify all present and prospective

employers of the decision in case number 4775 and the terms conditions and restrictions imposed

on Respondent Chung by the decision as follows

Within thirty (30) days ofthe effective date ofthis decision and within fifteen (15) days of

Respondent Chtmg undertaking any new employment Respondent Chung shall cause her direct

supervisor pharmacist-in-charge (including each new pharmacist-in-charge employed during

Respondent Chung s tenure of employment) and owner to report to the board in writing

acknowledging that the listed individual(s) hashave read the decision in case number 4775 and

terms and conditions imposed thereby It shall be Respondent Chungs responsibility to ensure

that her employer(s) andor supervisor(s) submit timely acknowledgment(s) to the board

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STIPULATED SETTLEMENT (4775) I

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-~

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-middot~-Jf)3~e_spo_rA~ntChl1ng V~rlcs for_or is ~mploye~ b)or tlyough (l Jh~JEaCY eJ11ployment

service Respondent Chung must notify her direct supervisor phannacist-in-charge and owner at

every entity ~icensed by the board of the terms arid conditions of the decision in case number

4775 in advance of the Respondent Chung commencing work at each licensed entity A record of

this notification mustbe provided to the board upon request

Furthemore within thiliy (30) days ofthe effective date of this decision and within fifteen

(15) days of Respondent Chung undertaking any Hew employment by or through a pharmacy

employment service Respondent Chlmg shall cause her direct supervisor with the pharmacy

employment service to report to the board in writing acknowledging that she has read the decision

in case number 4775 and the terms and conditions imposed thereby It shall be Respondent

Chlings respmisibility to ensure that her employer(s) andor supervisor(s) submit timely

acknowledgment(s) to the board

Failure to timely notify present or prospective employer(s) or to cause thatthose

employer(s) to submit timely acknowledgments to the board shall be considered a violation of

probation

Employment within the meaning of this provision shall include any full-time

pali-time temporary relief or pharmacy management service as a pharmacist or any

position for which a pharmacist license is a requirement or criterion for employment

whether the Respondent Chung is an employee independent contractor or volunteer

8 No Supervision oflnterns Serving as Pharmacist-in-Charge (PIC) Serving as Designated Representative-in-Charge or Serving as a Consultant

During the period of probation R~spondent Chlmg shall not supervise any intern

pharmacist be the pharmacist-in-charge or designated representative-in-charge of any entity

licensed by the board nor serve as a consultant unless otherwise specified in this order

Assumption of any such unauthorized supervision responsibilities shall middotbe considered a violation

of probation

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STIPULATED SETTLEMENT (4775)

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9 Reimbursement of Board Costs

As a condition precedent to successful completion of probation Respondent Chung shall

pay to the board its costs of investigation and prosecution in the amount of $826533

Respondent Chung shall make said payment on a payment plan approved by the board

There shall be no deviation from this schedule absent prior written middotapproval by the board or

its designee Failure to pay costs by the deadline(s) as directed shall be considered a violation of

probation

The filing of bankruptcy by Respondent Chung shall not relieve Respondent Chung of her

responsibility to reimburse the board its costs of investigation and prosecution

10 Probation Monitoring Costs

Respondent Chung shall pay any costs associated with probation monitoring as determined

by the board each and every year of probation Such costs shall be payable to the board on a

schedule as directed by the board or its designee Failure to pay such costs by the deadline(s) as

directed shall be considered a violation of probation

11 Status of License

Respondent Chung shall at all times while on probation maintain an active current license

with the boaid including any period during which suspension or probation is tolled Failure to

maintain an active current license shall be considered a violation of probation

IfRespondent ChLmg1s license expires or is cancelled by operation of law or otherwise at

any time during the period of probation including any extensions thereof due to tolling or

otherwise upon renewal or reapplication Respondent Chung1s license shall be subject to all terms

and conditions of this probation not previously satisfied

12 License Surrender While on ProbationSuspension

Following the effective date of this decision should Respondent Chung cease practice due

to retirement or health or be otherwise unable to satisfy the terms and conditions ofprobatiori

Respondent Chung maytender her license to the board for surrender The board or its designee

shall have the discretion whether to grant the request for surrender or take any other action it

deems appropriate and reasonable Upon formal acceptance of the surrender of the license

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STIPULATED SETTLEMENT ( 4 775)

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~~~E~-~d~n~__ ghu~will P-0 lltn~er be subject to ~e ~rrns an~ cndii_ol~ ofpro~a~ion This

surrender constitutes a record of discipline and shall become a part of the Respondent Chungs

license history with the board

Upon acceptance of the surrender Respondent Chung shall relinquish her pocket and wall

license to the board within ten ( 1 0) middotdays of notification by the board that the surrender is

accepted Respondent Chung may not reapply for any license from the board for three (3) years

from the effective date of the surrender Respondent Chung shall meet all requirements

applicable to the license sought as of the date the application for that license is submitted to the

board including any outstanding costs

13 Notification of a Change in N arne Residence Address Mailing Address or Employment middot

Respondent Chung shall notify the hoard in writing within ten (10) days of any change of

employment Said notification shall include the reasons for leaving the address of the new

~mployer the name ofthe supervise and owner and the work schedule ifknown Respondent

Chung shall further notify the board in writing within ten (1 0) days of a change in name

residence address mailing address or phone number

Failure to timely notify the board of any change in employer(s) name(s) address(es) or

phone number( s) shall be considered a violation of probation

14 Tolling of Probation

Except during periods of suspension Respondent Chung shall at all times while on

probation be employed as a pharmacist in California for a minimum of 40 hours per calendar

month Any month during which this minimum is not met shall toll the period of probation ie

the period ofpimiddotobation shall be extended by one month for each month during which this

minimum is not met During any such period oftolling of probation Respondent Chung must

nonetheless comply with all terms and conditions of probation

Should Respondent Chung regardless of residency for any reason (including vacation)

cease practicing as a pharmacist for a minimum of 40 hours per calendar month in California

Respondent Chung must notify the board in writing within ten (1 0) days of the cessation of

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STIPULATED SETTLEMENT ( 4775)

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practice and must further notify the board in writing within ten (1 0) days of the resumption of middotmiddot-middot -~ __ -- middot---middot- ~--

practice Any failure to provide such notification(s) shall be considered a violation of probation

It is a violation ofprobation for Respondent Chung1s probation to remain tolled pursuant to

the provisions of this condition for a total period counting consecutive and non-consecutive

months exceeding thirty-six (36) months

Cessation of practice means any cale~dar month during which Respondent

Chung is not practicing as a pharmacist for at least 40 hours as defined by Business

and Professions Code section 4000 et seq Resumption of practice means any

calendar month during which Respondent Chung is practicing as a pharmacist for at

least 40 hours as a pharmacist as defined by Business and Professions Code section

4000 et seq

15 Violation of Probation

If a Respondent Chung has not complied with any term or condition of probation the board

shall have continuing jurisdiction over Respondent Chung and probation shall automatically be

extended until all terms and conditions have been satisfied 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 that was stayed

If Respondent Chung violates probation in any respect the board after giving Respondent

Chung notice and an opportunity to be heard may revoke probation and carry out the disciplinary

order that was stayed Notice and opportunity to be heard are not required for those provisions

stating that a violation thereof may lead to automatic termination of the stay andor revocation of

the license If a petition to revoke probation or an accusation is filed against Respondent Chung

during probation the board shall have continuing jurisdiction and the period of probation shall be

automatically extended until the petition to revoke probation or accusation is heard and decided

16 Completion ofProbation

Upon written notice by the board or its designee indicating successful completion of

probation Respondent Chungs license will be fully restored

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STIPULATED SETTLEMENT (4775)

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17 Community Services Program middotmiddot--middot bull bullbull-bull _H_ bullI bull bullmiddotmiddotmiddotmiddotmiddot-~ bullmiddotbullbullo-middot bull bull~--middotmiddot-~---middotbull-bull~--bull-bullgtmiddotmiddot middotmiddotmiddotgtbull-bullmiddotbull -

Vilithin sixty (60) days of the effective date of this decision Respondent Chung shall submit

to the board or its designee for prior approval a community service program in which

Respondent Chung shall provide free health-care related services on a regular basis to a

middot

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community or charitable facility or agency foimiddot at least 64 hours per year for each year of

probation Within thirty (30) days ofboard approval thereof Respondent Chung shall submit

documentation to the board demonstrating commencement of the community service program A

record ofthis notification must be provided to the board upon request Respondent Chung shall

report on progress with the community service program in the quarterly reports Failure to timely

submit con1inenceor comply witi1 the program shall be considered a violation of probation

18 Remedial Education

Yfithin sixty (60) days of the effective date ofthis decision Respondent Chung shall submit

to the board or its designee for prior approval an appropriate program of remedial education

related to dispensing of controlled substances corresponding responsibility and appropriate

controlled substance therapy The program of remedial education shall consist of at least ten (1 0)

units which shall be completed within the first three years of probation at Respondent Chung1s

own expense All remedial education shall be in addition to and shall not be credited toward

continuing education (CE) courses used for license renewal purposes

Failure to timely submit or complete the approved remedial education shall be considered a

violation of probation The period of probation will be automatically extended until such

remedial education is successfully completed and writte1i proof in a form acceptable to the board

is provided to the board or its designee

Following the completion of each course the board or its designee may require the

Respondent Chung at her own expense to take an approved examination to test the Respondent

Chung1s knowledge of the course If the Respondent Chung does not achieve a passing score on

the examination this failure shall be considered a violation ofprobation Any such examination

failure shall require Respondent Chung to take another course approved by the board in the same

subject area

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19 Supervised Practi(e

During the period of probation Respondent Chung shall practice only under the supervision

of a licens~d pharmacist not on probation with the board Upon and after the effective date of this

decision Respondent Chung shall not practice pharmacy and her license shall be automatically

suspended until a supervisor is approved by the board or its designee The supervision shall be

as required by the board or its designee either

Continuous- At least 75 of a work week

Substantial - At least 50 of a wotk week

Partial- At least 25 of a work week

Daily Review- Supervisor1s review of probationer1S daily activities within 24 hours

Within thirty (30) days ofthe effective date of this decision Respondent Chung shall have

her supervisor submit notification to the board in writing stating that the supervisor has read the

decision iri case number 4775 and is familiar with the required level of supervision as determined

by the board or its designee It shall be the Respondent Chungs responsibility to ensme that her

employer(s) pharmacist-in-charge andor supervisor(s) submit timely acknowledgement(s) to the

board Failure to cause the direct supervisor and the pharmacist-in-charge to submit timely

acla1owledgements to the board shall be considered a violation of probation

If Respondent Chung changes employment it shall be the Respondent Chung s

responsibility to ensure that her employer(s) pharmacist-in-charge andor supervisor(s) submit

timely acknowledgement(s) to the board Respondent Chung shall have her new supervisor

within fifteen (15) days after employment commences submit notification to the board in writing

stating the direct supervisor and pharmacist-in-charge have read the decision in case number 4775

and is familiar with the level of supervision as determined by the board Respondent Chung shall

not practice pharmacy and her license shall be automatically suspended until the board or its

designee approves a new supervisor Failure to cause the direct supervisor and the phannacist-inshy

charge to submit timely acknowledgements to the board shall be considered a violation of

probation

Within ten (1 0) days of leaving employment Respondent Chung shall notify the board in

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STIPULATED SETTLEMENT (4775)

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writing

During suspension Respondent Chung shall not enter any pharmacy area or any portion of

the licensed premises of a wholesaler veterinary food-animal drug retailer or any other distributor

of drugs which is licensed by the board or any manufacturer or where dangerous drugs and

devices or controlled substances are maintained Respondent ChtmgBhallmiddotnotpractice pharmacy

nor do any act involving drug selection selection of stock manufacturing compounding

dispensing or patient consultation nor shall Respondent Chung 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 and controlled substances Respondent Chung shall not resume

practice until notified by the board

During suspension Respondent Chung shall not engage in any activity that requires the

professional judgment of a pharmacist Respondent Chung shall not direct or control any aspect

of the practice of pharmacy Respondent Chung shall not perform the duties of a pharmacy

technician or a designatedrepresentative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in arty licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwisespecified in thismiddot order

Failure to comply with this suspension shall be considered a violation of probation

20 No Ownership of Licensed Premises

Respondent Chung shall not own have any legal or beneficial interest in or serve as a

manager administrator member officer director trustee associate or partner of any business

firm pruinership or corporation currently or hereinafter licensed by the board Respondent

Chung shall sell or transfer any legal or beneficial interest in any entity licensed by the board

within ninety (90) days followiiig the effective date of this decision and shallimmediately

thereafter provide written proof thereof to the borumiddotd Failure to timely divest any legal or

beneficial interest(s) or provide documentation thereof shall be considered a violation of

probation

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STIPULATED SETTLEMENT (4775) I

r-----------------------------------------middot-middotmiddotmiddot-middotmiddot -

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21 Tolling of Suspension

During the period of suspension respondent shall not leave California for any period

exceeding ten (10) days regardless of purpose (including vacation) Any such absence in excess

ofthe (10) days d11ring suspension shall be considered a violation of probation Moreover any

absence from California during the period of suspension exceeding ten (1 0) days shall toll the

suspension ie the suspension shall be extended by one day for each day over ten (10) days

respondent is absent from California During any such period of tolling of suspension respondent

must nonetheless comply with all terms m1d conditions of probation

Respondent must notify the bomd in writing within ten (1 0) days of departure and must

further notify the board in writing within ten (1 0) days of return The f~ilure to provide such

notification(s) shall constitute a violation ofprobation Upon such departure m1d return

respondent shall not resume the practice ofpharmacy until notified by the board that the period of

middotsuspension has been satisfactorily completed

ACCEPTANCE

I have carefully read the above Stipulated Settlement and Disciplinary Order and have fully

discussed it with my attorney Benjamin Robert Margolis I understm1d the stipulation m1d the

effect it will have on my Original Pharmacist License I enter into this Stipulated Settlement and

Disciplinary Order voluntarily knowingly and intelligently and agree to be bound by the

Decision and Order of the Bommiddotd of Pharmacy

DATED I Anne Chon-Yin Chun ka A1me Chung

of

I have read m1d fully discussed with Respondent Chung the terms and conditions and other

matters contained in the above Stipulated2ettlet and Disciplinary Or~~middot~r__approve its form

and content middot ---~ -shy

DATED joj j1y ~ ~~middot-- bull J J~nj airul1Kobert Margolis

Lttorney for Respondent Chung

14 STIPULATED SETTLEMENT (4775)

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ENDORSEMENT

The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully

submitted for consideration by the Board of Pharmacy

Dated D -I - ~ Respectfully submitted

KAMALA D HARRIS Attorney General of California MARC D GREENBAUM Supervising Deputy Atton1ey General

GILLIAN E FRIEDMAN Deputy Attorney General Attorneys for Complainant

LA2013509837 51608369doc

15

STIPULATED SETTLEMENT (4775)

Exhibit A

Accusation No 4775

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KAMALA D HARRlS A ttomey General of California MARC D GREENBAUM SuperVisingDeputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207 middot 300 So Spring Street Suite 1702

Los Angeles CA 90013 Telephone (213)897-2564 Facsimile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OF PHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Again~t

RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 PharmacyPermit No PHY 42331

ANNE CHON-YIN CHUNG 3 782 Moore Street Los Angeles CA 90066 Original Pharmacist License No RPH 40932

Respondents

Case No 4775

ACCUSATION

Complainant alleges

PARTIEsmiddot

1 Virginia Herold (Complainant) brings this Accusation solely in her official capacity

as the Executive Officer ofthe Board ofPharmacyDepartment of Consumer Affa)rs

2 On or about February 21 1997 the Board of Pharmacy issued Pharmacy Permit

Number PHY 42331 to Rite Aid 5429 located at 500 S Broadway Los Angeles California

90013-2302 (Respondent Rite Aid Pharmacy) The Pharmacy Permit was in full force and effect

Accusation

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at all times relevant to the charges brought herein and will expire on April 1 2014 unless

renewed

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932to Anne Chon-Yin Chu11g aka Anne Chung (Respondent Chung) The

Original Pharmacy License was in full force and effect at all times relevant to the charges brought

herein and will expire on January 312015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Respondent Rite Aiel Pharmacy

JURISDICTION

5 This Accusation is brought before the Board ofPharmacy (Board) Department of

Consumer Affairs under the authority onhe following laws All section references are to the

Business and Professions Code unless otherwise indicated

6 Section 4300 ofthe Code states

(a) Every license issued may be suspended or revoked

7 Section 4301 ofthe Code states

The board shall take action against any holder of a license who is guilty of unprofessional

conduct or whose license has been procured byfraud or misrepresentation or issued by mistake

Unprofessional conduct shall include but is not limited to any of the following

(a) Gross immorality

(b) Incompetence

(c) Gross negligence

(d) The clearly excessive furnishing of controiled substances in violation of subdivision (a)

of Section 11153 of the Health and Safety Code

(e) The cearly ~xces~iye furnishing of controlled substances in viqlation of subdivisiol (a)

of Section 111535 of the Health and Safety Code Factors to be considered in determining

whether the furnishing of controlled substances is clearly excessive shall include but not be

limited to the amount of controlled substances furnished the previous ordering pattern of the

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Accusation

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customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

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Accusation

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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Accusation

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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Accusation

(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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Accusation I

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

8 Accusation

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21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

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Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

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Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

i 13I

I 14I I ll

16

17

18

19

21

22

23

24

26

27

28

a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

12

Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

2

3

4

5

6

7

8

9

1o 11

12

13

14 middot

15

16

17

18 middot

19

20

21

22

23

24

25

26

27

28

supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

l

2

3

4

5

6

7

8

9

1o 11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

f4

16

17

18

19

21

22

middot 23

24

26

27

28

e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

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6

7

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1 0

11

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e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

5

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15

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25

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s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

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middot17

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middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

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I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

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ZO

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middot23

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f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

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middot 23

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

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-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

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bull

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

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middot1 0

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middot

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e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

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Accusation

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Respondent Chung shall not engage in any activity that requires the professionll judgment bullbull middotmiddotmiddotmiddotbull -~middotmiddotmiddot bull middotbullbull bull bull bull bull bull bull bull bull bull -middot bull - bull middot-middot bull bull bull bull

of a pharmacist Respondent Chung shall not direct or control any aspect of the practice of

phannacy Respondent Chung shall not perform the duties of a pharmacy technician or a

designated representative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in aliy licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwise speCified in this order

Failure to comply with this suspension shall be considered a violation of probation

2 Obey All Laws

Respondent Chung shall obey all state and federal laws and regulations

Respondent Chung shall report any of the following occurrences to the board in writing

within seventy-two (72) hours of such occunence

bull an anest or issuance of a criminal complaint for violation of any provision of the

Pharmacy Law state and federal food and drug laws or state and federal controlled

substances laws

bull a plea of guilty or nolo contendre in any state or federal criminal proceeding to any

criminal complaint information or indictment

bull a conviction of any crime

discipline citation or other administrative action filed by any state or federal agency

which involves Respondent Chungs Pharmacist License or which is related to the

practice of pharmacy or the manufacturing obtaining handling distributing billing

or charging for any drug device or controlled substance

Failure to timely report such occurrence shall be considered middota violation of probation

3 Report to the Board

Respondent Chung shall ryport to the board quarterly on a schedule as directed by the

board or its designee The report shall be made either in person or in writing as directed Among

other requirements Respondent Chung shall state in each report under penalty of perjury whether

there has been compliance with all the terms and conditions of probation Failure to submit

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STIPULATED SETTLEMENT (4775)

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_fmely reports in a f~rrn a~ directed shall be considered a violation ofprobation Any period(s) of middot- bull middotmiddotmiddot-middot middot- middot middot-

delinquency in submission of reports as directed may be added to the total period of probation

Moreover if the final probation report is not made as directed probation shall be automatically

extended w1til such time as the final report is made and accepted by the board

4 Interview with the Board

Upon receipt of reasonable prior notice Respondent Chung shall appear in person for

interviews with the board or its designee at such intervals and locations as are determined by the

board or its designee Failure to appear for any scheduled interview without prior notification to

board staff or failure to appear for two (2) or more scheduled interviews with the board or its

designee during the period of probation shall be considered a violation of probation

5 Cooperate with Board Staff

Respondent Chung shall cooperate with the boards inspection program and with the boards

monitoring and investigation of Respondent Chungs compliance with the terms and conditions of

her probation Failure to cooperate shall be considered a violation of probation

6 Continuing Education

Respondent Chung shall provide evidence of efforts to maintain skill and knowledge as a

pharmacist as directed by the board or its designee

7 Notice to Employers

During the period of probation Respondent Chung shall notify all present and prospective

employers of the decision in case number 4775 and the terms conditions and restrictions imposed

on Respondent Chung by the decision as follows

Within thirty (30) days ofthe effective date ofthis decision and within fifteen (15) days of

Respondent Chtmg undertaking any new employment Respondent Chung shall cause her direct

supervisor pharmacist-in-charge (including each new pharmacist-in-charge employed during

Respondent Chung s tenure of employment) and owner to report to the board in writing

acknowledging that the listed individual(s) hashave read the decision in case number 4775 and

terms and conditions imposed thereby It shall be Respondent Chungs responsibility to ensure

that her employer(s) andor supervisor(s) submit timely acknowledgment(s) to the board

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STIPULATED SETTLEMENT (4775) I

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-~

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-middot~-Jf)3~e_spo_rA~ntChl1ng V~rlcs for_or is ~mploye~ b)or tlyough (l Jh~JEaCY eJ11ployment

service Respondent Chung must notify her direct supervisor phannacist-in-charge and owner at

every entity ~icensed by the board of the terms arid conditions of the decision in case number

4775 in advance of the Respondent Chung commencing work at each licensed entity A record of

this notification mustbe provided to the board upon request

Furthemore within thiliy (30) days ofthe effective date of this decision and within fifteen

(15) days of Respondent Chung undertaking any Hew employment by or through a pharmacy

employment service Respondent Chlmg shall cause her direct supervisor with the pharmacy

employment service to report to the board in writing acknowledging that she has read the decision

in case number 4775 and the terms and conditions imposed thereby It shall be Respondent

Chlings respmisibility to ensure that her employer(s) andor supervisor(s) submit timely

acknowledgment(s) to the board

Failure to timely notify present or prospective employer(s) or to cause thatthose

employer(s) to submit timely acknowledgments to the board shall be considered a violation of

probation

Employment within the meaning of this provision shall include any full-time

pali-time temporary relief or pharmacy management service as a pharmacist or any

position for which a pharmacist license is a requirement or criterion for employment

whether the Respondent Chung is an employee independent contractor or volunteer

8 No Supervision oflnterns Serving as Pharmacist-in-Charge (PIC) Serving as Designated Representative-in-Charge or Serving as a Consultant

During the period of probation R~spondent Chlmg shall not supervise any intern

pharmacist be the pharmacist-in-charge or designated representative-in-charge of any entity

licensed by the board nor serve as a consultant unless otherwise specified in this order

Assumption of any such unauthorized supervision responsibilities shall middotbe considered a violation

of probation

7

STIPULATED SETTLEMENT (4775)

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9 Reimbursement of Board Costs

As a condition precedent to successful completion of probation Respondent Chung shall

pay to the board its costs of investigation and prosecution in the amount of $826533

Respondent Chung shall make said payment on a payment plan approved by the board

There shall be no deviation from this schedule absent prior written middotapproval by the board or

its designee Failure to pay costs by the deadline(s) as directed shall be considered a violation of

probation

The filing of bankruptcy by Respondent Chung shall not relieve Respondent Chung of her

responsibility to reimburse the board its costs of investigation and prosecution

10 Probation Monitoring Costs

Respondent Chung shall pay any costs associated with probation monitoring as determined

by the board each and every year of probation Such costs shall be payable to the board on a

schedule as directed by the board or its designee Failure to pay such costs by the deadline(s) as

directed shall be considered a violation of probation

11 Status of License

Respondent Chung shall at all times while on probation maintain an active current license

with the boaid including any period during which suspension or probation is tolled Failure to

maintain an active current license shall be considered a violation of probation

IfRespondent ChLmg1s license expires or is cancelled by operation of law or otherwise at

any time during the period of probation including any extensions thereof due to tolling or

otherwise upon renewal or reapplication Respondent Chung1s license shall be subject to all terms

and conditions of this probation not previously satisfied

12 License Surrender While on ProbationSuspension

Following the effective date of this decision should Respondent Chung cease practice due

to retirement or health or be otherwise unable to satisfy the terms and conditions ofprobatiori

Respondent Chung maytender her license to the board for surrender The board or its designee

shall have the discretion whether to grant the request for surrender or take any other action it

deems appropriate and reasonable Upon formal acceptance of the surrender of the license

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STIPULATED SETTLEMENT ( 4 775)

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~~~E~-~d~n~__ ghu~will P-0 lltn~er be subject to ~e ~rrns an~ cndii_ol~ ofpro~a~ion This

surrender constitutes a record of discipline and shall become a part of the Respondent Chungs

license history with the board

Upon acceptance of the surrender Respondent Chung shall relinquish her pocket and wall

license to the board within ten ( 1 0) middotdays of notification by the board that the surrender is

accepted Respondent Chung may not reapply for any license from the board for three (3) years

from the effective date of the surrender Respondent Chung shall meet all requirements

applicable to the license sought as of the date the application for that license is submitted to the

board including any outstanding costs

13 Notification of a Change in N arne Residence Address Mailing Address or Employment middot

Respondent Chung shall notify the hoard in writing within ten (10) days of any change of

employment Said notification shall include the reasons for leaving the address of the new

~mployer the name ofthe supervise and owner and the work schedule ifknown Respondent

Chung shall further notify the board in writing within ten (1 0) days of a change in name

residence address mailing address or phone number

Failure to timely notify the board of any change in employer(s) name(s) address(es) or

phone number( s) shall be considered a violation of probation

14 Tolling of Probation

Except during periods of suspension Respondent Chung shall at all times while on

probation be employed as a pharmacist in California for a minimum of 40 hours per calendar

month Any month during which this minimum is not met shall toll the period of probation ie

the period ofpimiddotobation shall be extended by one month for each month during which this

minimum is not met During any such period oftolling of probation Respondent Chung must

nonetheless comply with all terms and conditions of probation

Should Respondent Chung regardless of residency for any reason (including vacation)

cease practicing as a pharmacist for a minimum of 40 hours per calendar month in California

Respondent Chung must notify the board in writing within ten (1 0) days of the cessation of

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STIPULATED SETTLEMENT ( 4775)

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practice and must further notify the board in writing within ten (1 0) days of the resumption of middotmiddot-middot -~ __ -- middot---middot- ~--

practice Any failure to provide such notification(s) shall be considered a violation of probation

It is a violation ofprobation for Respondent Chung1s probation to remain tolled pursuant to

the provisions of this condition for a total period counting consecutive and non-consecutive

months exceeding thirty-six (36) months

Cessation of practice means any cale~dar month during which Respondent

Chung is not practicing as a pharmacist for at least 40 hours as defined by Business

and Professions Code section 4000 et seq Resumption of practice means any

calendar month during which Respondent Chung is practicing as a pharmacist for at

least 40 hours as a pharmacist as defined by Business and Professions Code section

4000 et seq

15 Violation of Probation

If a Respondent Chung has not complied with any term or condition of probation the board

shall have continuing jurisdiction over Respondent Chung and probation shall automatically be

extended until all terms and conditions have been satisfied 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 that was stayed

If Respondent Chung violates probation in any respect the board after giving Respondent

Chung notice and an opportunity to be heard may revoke probation and carry out the disciplinary

order that was stayed Notice and opportunity to be heard are not required for those provisions

stating that a violation thereof may lead to automatic termination of the stay andor revocation of

the license If a petition to revoke probation or an accusation is filed against Respondent Chung

during probation the board shall have continuing jurisdiction and the period of probation shall be

automatically extended until the petition to revoke probation or accusation is heard and decided

16 Completion ofProbation

Upon written notice by the board or its designee indicating successful completion of

probation Respondent Chungs license will be fully restored

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STIPULATED SETTLEMENT (4775)

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17 Community Services Program middotmiddot--middot bull bullbull-bull _H_ bullI bull bullmiddotmiddotmiddotmiddotmiddot-~ bullmiddotbullbullo-middot bull bull~--middotmiddot-~---middotbull-bull~--bull-bullgtmiddotmiddot middotmiddotmiddotgtbull-bullmiddotbull -

Vilithin sixty (60) days of the effective date of this decision Respondent Chung shall submit

to the board or its designee for prior approval a community service program in which

Respondent Chung shall provide free health-care related services on a regular basis to a

middot

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community or charitable facility or agency foimiddot at least 64 hours per year for each year of

probation Within thirty (30) days ofboard approval thereof Respondent Chung shall submit

documentation to the board demonstrating commencement of the community service program A

record ofthis notification must be provided to the board upon request Respondent Chung shall

report on progress with the community service program in the quarterly reports Failure to timely

submit con1inenceor comply witi1 the program shall be considered a violation of probation

18 Remedial Education

Yfithin sixty (60) days of the effective date ofthis decision Respondent Chung shall submit

to the board or its designee for prior approval an appropriate program of remedial education

related to dispensing of controlled substances corresponding responsibility and appropriate

controlled substance therapy The program of remedial education shall consist of at least ten (1 0)

units which shall be completed within the first three years of probation at Respondent Chung1s

own expense All remedial education shall be in addition to and shall not be credited toward

continuing education (CE) courses used for license renewal purposes

Failure to timely submit or complete the approved remedial education shall be considered a

violation of probation The period of probation will be automatically extended until such

remedial education is successfully completed and writte1i proof in a form acceptable to the board

is provided to the board or its designee

Following the completion of each course the board or its designee may require the

Respondent Chung at her own expense to take an approved examination to test the Respondent

Chung1s knowledge of the course If the Respondent Chung does not achieve a passing score on

the examination this failure shall be considered a violation ofprobation Any such examination

failure shall require Respondent Chung to take another course approved by the board in the same

subject area

11

STIPULATED SETTLEMENT (4775) I

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19 Supervised Practi(e

During the period of probation Respondent Chung shall practice only under the supervision

of a licens~d pharmacist not on probation with the board Upon and after the effective date of this

decision Respondent Chung shall not practice pharmacy and her license shall be automatically

suspended until a supervisor is approved by the board or its designee The supervision shall be

as required by the board or its designee either

Continuous- At least 75 of a work week

Substantial - At least 50 of a wotk week

Partial- At least 25 of a work week

Daily Review- Supervisor1s review of probationer1S daily activities within 24 hours

Within thirty (30) days ofthe effective date of this decision Respondent Chung shall have

her supervisor submit notification to the board in writing stating that the supervisor has read the

decision iri case number 4775 and is familiar with the required level of supervision as determined

by the board or its designee It shall be the Respondent Chungs responsibility to ensme that her

employer(s) pharmacist-in-charge andor supervisor(s) submit timely acknowledgement(s) to the

board Failure to cause the direct supervisor and the pharmacist-in-charge to submit timely

acla1owledgements to the board shall be considered a violation of probation

If Respondent Chung changes employment it shall be the Respondent Chung s

responsibility to ensure that her employer(s) pharmacist-in-charge andor supervisor(s) submit

timely acknowledgement(s) to the board Respondent Chung shall have her new supervisor

within fifteen (15) days after employment commences submit notification to the board in writing

stating the direct supervisor and pharmacist-in-charge have read the decision in case number 4775

and is familiar with the level of supervision as determined by the board Respondent Chung shall

not practice pharmacy and her license shall be automatically suspended until the board or its

designee approves a new supervisor Failure to cause the direct supervisor and the phannacist-inshy

charge to submit timely acknowledgements to the board shall be considered a violation of

probation

Within ten (1 0) days of leaving employment Respondent Chung shall notify the board in

12

STIPULATED SETTLEMENT (4775)

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writing

During suspension Respondent Chung shall not enter any pharmacy area or any portion of

the licensed premises of a wholesaler veterinary food-animal drug retailer or any other distributor

of drugs which is licensed by the board or any manufacturer or where dangerous drugs and

devices or controlled substances are maintained Respondent ChtmgBhallmiddotnotpractice pharmacy

nor do any act involving drug selection selection of stock manufacturing compounding

dispensing or patient consultation nor shall Respondent Chung 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 and controlled substances Respondent Chung shall not resume

practice until notified by the board

During suspension Respondent Chung shall not engage in any activity that requires the

professional judgment of a pharmacist Respondent Chung shall not direct or control any aspect

of the practice of pharmacy Respondent Chung shall not perform the duties of a pharmacy

technician or a designatedrepresentative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in arty licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwisespecified in thismiddot order

Failure to comply with this suspension shall be considered a violation of probation

20 No Ownership of Licensed Premises

Respondent Chung shall not own have any legal or beneficial interest in or serve as a

manager administrator member officer director trustee associate or partner of any business

firm pruinership or corporation currently or hereinafter licensed by the board Respondent

Chung shall sell or transfer any legal or beneficial interest in any entity licensed by the board

within ninety (90) days followiiig the effective date of this decision and shallimmediately

thereafter provide written proof thereof to the borumiddotd Failure to timely divest any legal or

beneficial interest(s) or provide documentation thereof shall be considered a violation of

probation

13

STIPULATED SETTLEMENT (4775) I

r-----------------------------------------middot-middotmiddotmiddot-middotmiddot -

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21 Tolling of Suspension

During the period of suspension respondent shall not leave California for any period

exceeding ten (10) days regardless of purpose (including vacation) Any such absence in excess

ofthe (10) days d11ring suspension shall be considered a violation of probation Moreover any

absence from California during the period of suspension exceeding ten (1 0) days shall toll the

suspension ie the suspension shall be extended by one day for each day over ten (10) days

respondent is absent from California During any such period of tolling of suspension respondent

must nonetheless comply with all terms m1d conditions of probation

Respondent must notify the bomd in writing within ten (1 0) days of departure and must

further notify the board in writing within ten (1 0) days of return The f~ilure to provide such

notification(s) shall constitute a violation ofprobation Upon such departure m1d return

respondent shall not resume the practice ofpharmacy until notified by the board that the period of

middotsuspension has been satisfactorily completed

ACCEPTANCE

I have carefully read the above Stipulated Settlement and Disciplinary Order and have fully

discussed it with my attorney Benjamin Robert Margolis I understm1d the stipulation m1d the

effect it will have on my Original Pharmacist License I enter into this Stipulated Settlement and

Disciplinary Order voluntarily knowingly and intelligently and agree to be bound by the

Decision and Order of the Bommiddotd of Pharmacy

DATED I Anne Chon-Yin Chun ka A1me Chung

of

I have read m1d fully discussed with Respondent Chung the terms and conditions and other

matters contained in the above Stipulated2ettlet and Disciplinary Or~~middot~r__approve its form

and content middot ---~ -shy

DATED joj j1y ~ ~~middot-- bull J J~nj airul1Kobert Margolis

Lttorney for Respondent Chung

14 STIPULATED SETTLEMENT (4775)

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ENDORSEMENT

The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully

submitted for consideration by the Board of Pharmacy

Dated D -I - ~ Respectfully submitted

KAMALA D HARRIS Attorney General of California MARC D GREENBAUM Supervising Deputy Atton1ey General

GILLIAN E FRIEDMAN Deputy Attorney General Attorneys for Complainant

LA2013509837 51608369doc

15

STIPULATED SETTLEMENT (4775)

Exhibit A

Accusation No 4775

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KAMALA D HARRlS A ttomey General of California MARC D GREENBAUM SuperVisingDeputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207 middot 300 So Spring Street Suite 1702

Los Angeles CA 90013 Telephone (213)897-2564 Facsimile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OF PHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Again~t

RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 PharmacyPermit No PHY 42331

ANNE CHON-YIN CHUNG 3 782 Moore Street Los Angeles CA 90066 Original Pharmacist License No RPH 40932

Respondents

Case No 4775

ACCUSATION

Complainant alleges

PARTIEsmiddot

1 Virginia Herold (Complainant) brings this Accusation solely in her official capacity

as the Executive Officer ofthe Board ofPharmacyDepartment of Consumer Affa)rs

2 On or about February 21 1997 the Board of Pharmacy issued Pharmacy Permit

Number PHY 42331 to Rite Aid 5429 located at 500 S Broadway Los Angeles California

90013-2302 (Respondent Rite Aid Pharmacy) The Pharmacy Permit was in full force and effect

Accusation

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at all times relevant to the charges brought herein and will expire on April 1 2014 unless

renewed

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932to Anne Chon-Yin Chu11g aka Anne Chung (Respondent Chung) The

Original Pharmacy License was in full force and effect at all times relevant to the charges brought

herein and will expire on January 312015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Respondent Rite Aiel Pharmacy

JURISDICTION

5 This Accusation is brought before the Board ofPharmacy (Board) Department of

Consumer Affairs under the authority onhe following laws All section references are to the

Business and Professions Code unless otherwise indicated

6 Section 4300 ofthe Code states

(a) Every license issued may be suspended or revoked

7 Section 4301 ofthe Code states

The board shall take action against any holder of a license who is guilty of unprofessional

conduct or whose license has been procured byfraud or misrepresentation or issued by mistake

Unprofessional conduct shall include but is not limited to any of the following

(a) Gross immorality

(b) Incompetence

(c) Gross negligence

(d) The clearly excessive furnishing of controiled substances in violation of subdivision (a)

of Section 11153 of the Health and Safety Code

(e) The cearly ~xces~iye furnishing of controlled substances in viqlation of subdivisiol (a)

of Section 111535 of the Health and Safety Code Factors to be considered in determining

whether the furnishing of controlled substances is clearly excessive shall include but not be

limited to the amount of controlled substances furnished the previous ordering pattern of the

2

Accusation

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customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

3

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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Accusation

(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

8 Accusation

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middot

21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

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Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

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a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

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Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

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supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

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r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

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1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

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Accusation

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e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

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e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

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s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

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23

24

25

26

27

28

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

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24

25

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28

middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

3

4

5

6

7

8

9

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17

18

19

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23

24

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28

I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

9

10

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21

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24

25 I

26

27

28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

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26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

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17

18

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middot 23

24

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28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

2

3

4

5

6

7

8

9

10

11

12

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15

16

17

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19

20

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

10

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25

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3

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-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

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bull

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

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middot1 0

11

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middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

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_fmely reports in a f~rrn a~ directed shall be considered a violation ofprobation Any period(s) of middot- bull middotmiddotmiddot-middot middot- middot middot-

delinquency in submission of reports as directed may be added to the total period of probation

Moreover if the final probation report is not made as directed probation shall be automatically

extended w1til such time as the final report is made and accepted by the board

4 Interview with the Board

Upon receipt of reasonable prior notice Respondent Chung shall appear in person for

interviews with the board or its designee at such intervals and locations as are determined by the

board or its designee Failure to appear for any scheduled interview without prior notification to

board staff or failure to appear for two (2) or more scheduled interviews with the board or its

designee during the period of probation shall be considered a violation of probation

5 Cooperate with Board Staff

Respondent Chung shall cooperate with the boards inspection program and with the boards

monitoring and investigation of Respondent Chungs compliance with the terms and conditions of

her probation Failure to cooperate shall be considered a violation of probation

6 Continuing Education

Respondent Chung shall provide evidence of efforts to maintain skill and knowledge as a

pharmacist as directed by the board or its designee

7 Notice to Employers

During the period of probation Respondent Chung shall notify all present and prospective

employers of the decision in case number 4775 and the terms conditions and restrictions imposed

on Respondent Chung by the decision as follows

Within thirty (30) days ofthe effective date ofthis decision and within fifteen (15) days of

Respondent Chtmg undertaking any new employment Respondent Chung shall cause her direct

supervisor pharmacist-in-charge (including each new pharmacist-in-charge employed during

Respondent Chung s tenure of employment) and owner to report to the board in writing

acknowledging that the listed individual(s) hashave read the decision in case number 4775 and

terms and conditions imposed thereby It shall be Respondent Chungs responsibility to ensure

that her employer(s) andor supervisor(s) submit timely acknowledgment(s) to the board

6

STIPULATED SETTLEMENT (4775) I

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-~

Ill

Ill

-middot~-Jf)3~e_spo_rA~ntChl1ng V~rlcs for_or is ~mploye~ b)or tlyough (l Jh~JEaCY eJ11ployment

service Respondent Chung must notify her direct supervisor phannacist-in-charge and owner at

every entity ~icensed by the board of the terms arid conditions of the decision in case number

4775 in advance of the Respondent Chung commencing work at each licensed entity A record of

this notification mustbe provided to the board upon request

Furthemore within thiliy (30) days ofthe effective date of this decision and within fifteen

(15) days of Respondent Chung undertaking any Hew employment by or through a pharmacy

employment service Respondent Chlmg shall cause her direct supervisor with the pharmacy

employment service to report to the board in writing acknowledging that she has read the decision

in case number 4775 and the terms and conditions imposed thereby It shall be Respondent

Chlings respmisibility to ensure that her employer(s) andor supervisor(s) submit timely

acknowledgment(s) to the board

Failure to timely notify present or prospective employer(s) or to cause thatthose

employer(s) to submit timely acknowledgments to the board shall be considered a violation of

probation

Employment within the meaning of this provision shall include any full-time

pali-time temporary relief or pharmacy management service as a pharmacist or any

position for which a pharmacist license is a requirement or criterion for employment

whether the Respondent Chung is an employee independent contractor or volunteer

8 No Supervision oflnterns Serving as Pharmacist-in-Charge (PIC) Serving as Designated Representative-in-Charge or Serving as a Consultant

During the period of probation R~spondent Chlmg shall not supervise any intern

pharmacist be the pharmacist-in-charge or designated representative-in-charge of any entity

licensed by the board nor serve as a consultant unless otherwise specified in this order

Assumption of any such unauthorized supervision responsibilities shall middotbe considered a violation

of probation

7

STIPULATED SETTLEMENT (4775)

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9 Reimbursement of Board Costs

As a condition precedent to successful completion of probation Respondent Chung shall

pay to the board its costs of investigation and prosecution in the amount of $826533

Respondent Chung shall make said payment on a payment plan approved by the board

There shall be no deviation from this schedule absent prior written middotapproval by the board or

its designee Failure to pay costs by the deadline(s) as directed shall be considered a violation of

probation

The filing of bankruptcy by Respondent Chung shall not relieve Respondent Chung of her

responsibility to reimburse the board its costs of investigation and prosecution

10 Probation Monitoring Costs

Respondent Chung shall pay any costs associated with probation monitoring as determined

by the board each and every year of probation Such costs shall be payable to the board on a

schedule as directed by the board or its designee Failure to pay such costs by the deadline(s) as

directed shall be considered a violation of probation

11 Status of License

Respondent Chung shall at all times while on probation maintain an active current license

with the boaid including any period during which suspension or probation is tolled Failure to

maintain an active current license shall be considered a violation of probation

IfRespondent ChLmg1s license expires or is cancelled by operation of law or otherwise at

any time during the period of probation including any extensions thereof due to tolling or

otherwise upon renewal or reapplication Respondent Chung1s license shall be subject to all terms

and conditions of this probation not previously satisfied

12 License Surrender While on ProbationSuspension

Following the effective date of this decision should Respondent Chung cease practice due

to retirement or health or be otherwise unable to satisfy the terms and conditions ofprobatiori

Respondent Chung maytender her license to the board for surrender The board or its designee

shall have the discretion whether to grant the request for surrender or take any other action it

deems appropriate and reasonable Upon formal acceptance of the surrender of the license

8

STIPULATED SETTLEMENT ( 4 775)

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~~~E~-~d~n~__ ghu~will P-0 lltn~er be subject to ~e ~rrns an~ cndii_ol~ ofpro~a~ion This

surrender constitutes a record of discipline and shall become a part of the Respondent Chungs

license history with the board

Upon acceptance of the surrender Respondent Chung shall relinquish her pocket and wall

license to the board within ten ( 1 0) middotdays of notification by the board that the surrender is

accepted Respondent Chung may not reapply for any license from the board for three (3) years

from the effective date of the surrender Respondent Chung shall meet all requirements

applicable to the license sought as of the date the application for that license is submitted to the

board including any outstanding costs

13 Notification of a Change in N arne Residence Address Mailing Address or Employment middot

Respondent Chung shall notify the hoard in writing within ten (10) days of any change of

employment Said notification shall include the reasons for leaving the address of the new

~mployer the name ofthe supervise and owner and the work schedule ifknown Respondent

Chung shall further notify the board in writing within ten (1 0) days of a change in name

residence address mailing address or phone number

Failure to timely notify the board of any change in employer(s) name(s) address(es) or

phone number( s) shall be considered a violation of probation

14 Tolling of Probation

Except during periods of suspension Respondent Chung shall at all times while on

probation be employed as a pharmacist in California for a minimum of 40 hours per calendar

month Any month during which this minimum is not met shall toll the period of probation ie

the period ofpimiddotobation shall be extended by one month for each month during which this

minimum is not met During any such period oftolling of probation Respondent Chung must

nonetheless comply with all terms and conditions of probation

Should Respondent Chung regardless of residency for any reason (including vacation)

cease practicing as a pharmacist for a minimum of 40 hours per calendar month in California

Respondent Chung must notify the board in writing within ten (1 0) days of the cessation of

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practice and must further notify the board in writing within ten (1 0) days of the resumption of middotmiddot-middot -~ __ -- middot---middot- ~--

practice Any failure to provide such notification(s) shall be considered a violation of probation

It is a violation ofprobation for Respondent Chung1s probation to remain tolled pursuant to

the provisions of this condition for a total period counting consecutive and non-consecutive

months exceeding thirty-six (36) months

Cessation of practice means any cale~dar month during which Respondent

Chung is not practicing as a pharmacist for at least 40 hours as defined by Business

and Professions Code section 4000 et seq Resumption of practice means any

calendar month during which Respondent Chung is practicing as a pharmacist for at

least 40 hours as a pharmacist as defined by Business and Professions Code section

4000 et seq

15 Violation of Probation

If a Respondent Chung has not complied with any term or condition of probation the board

shall have continuing jurisdiction over Respondent Chung and probation shall automatically be

extended until all terms and conditions have been satisfied 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 that was stayed

If Respondent Chung violates probation in any respect the board after giving Respondent

Chung notice and an opportunity to be heard may revoke probation and carry out the disciplinary

order that was stayed Notice and opportunity to be heard are not required for those provisions

stating that a violation thereof may lead to automatic termination of the stay andor revocation of

the license If a petition to revoke probation or an accusation is filed against Respondent Chung

during probation the board shall have continuing jurisdiction and the period of probation shall be

automatically extended until the petition to revoke probation or accusation is heard and decided

16 Completion ofProbation

Upon written notice by the board or its designee indicating successful completion of

probation Respondent Chungs license will be fully restored

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STIPULATED SETTLEMENT (4775)

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17 Community Services Program middotmiddot--middot bull bullbull-bull _H_ bullI bull bullmiddotmiddotmiddotmiddotmiddot-~ bullmiddotbullbullo-middot bull bull~--middotmiddot-~---middotbull-bull~--bull-bullgtmiddotmiddot middotmiddotmiddotgtbull-bullmiddotbull -

Vilithin sixty (60) days of the effective date of this decision Respondent Chung shall submit

to the board or its designee for prior approval a community service program in which

Respondent Chung shall provide free health-care related services on a regular basis to a

middot

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community or charitable facility or agency foimiddot at least 64 hours per year for each year of

probation Within thirty (30) days ofboard approval thereof Respondent Chung shall submit

documentation to the board demonstrating commencement of the community service program A

record ofthis notification must be provided to the board upon request Respondent Chung shall

report on progress with the community service program in the quarterly reports Failure to timely

submit con1inenceor comply witi1 the program shall be considered a violation of probation

18 Remedial Education

Yfithin sixty (60) days of the effective date ofthis decision Respondent Chung shall submit

to the board or its designee for prior approval an appropriate program of remedial education

related to dispensing of controlled substances corresponding responsibility and appropriate

controlled substance therapy The program of remedial education shall consist of at least ten (1 0)

units which shall be completed within the first three years of probation at Respondent Chung1s

own expense All remedial education shall be in addition to and shall not be credited toward

continuing education (CE) courses used for license renewal purposes

Failure to timely submit or complete the approved remedial education shall be considered a

violation of probation The period of probation will be automatically extended until such

remedial education is successfully completed and writte1i proof in a form acceptable to the board

is provided to the board or its designee

Following the completion of each course the board or its designee may require the

Respondent Chung at her own expense to take an approved examination to test the Respondent

Chung1s knowledge of the course If the Respondent Chung does not achieve a passing score on

the examination this failure shall be considered a violation ofprobation Any such examination

failure shall require Respondent Chung to take another course approved by the board in the same

subject area

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STIPULATED SETTLEMENT (4775) I

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19 Supervised Practi(e

During the period of probation Respondent Chung shall practice only under the supervision

of a licens~d pharmacist not on probation with the board Upon and after the effective date of this

decision Respondent Chung shall not practice pharmacy and her license shall be automatically

suspended until a supervisor is approved by the board or its designee The supervision shall be

as required by the board or its designee either

Continuous- At least 75 of a work week

Substantial - At least 50 of a wotk week

Partial- At least 25 of a work week

Daily Review- Supervisor1s review of probationer1S daily activities within 24 hours

Within thirty (30) days ofthe effective date of this decision Respondent Chung shall have

her supervisor submit notification to the board in writing stating that the supervisor has read the

decision iri case number 4775 and is familiar with the required level of supervision as determined

by the board or its designee It shall be the Respondent Chungs responsibility to ensme that her

employer(s) pharmacist-in-charge andor supervisor(s) submit timely acknowledgement(s) to the

board Failure to cause the direct supervisor and the pharmacist-in-charge to submit timely

acla1owledgements to the board shall be considered a violation of probation

If Respondent Chung changes employment it shall be the Respondent Chung s

responsibility to ensure that her employer(s) pharmacist-in-charge andor supervisor(s) submit

timely acknowledgement(s) to the board Respondent Chung shall have her new supervisor

within fifteen (15) days after employment commences submit notification to the board in writing

stating the direct supervisor and pharmacist-in-charge have read the decision in case number 4775

and is familiar with the level of supervision as determined by the board Respondent Chung shall

not practice pharmacy and her license shall be automatically suspended until the board or its

designee approves a new supervisor Failure to cause the direct supervisor and the phannacist-inshy

charge to submit timely acknowledgements to the board shall be considered a violation of

probation

Within ten (1 0) days of leaving employment Respondent Chung shall notify the board in

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STIPULATED SETTLEMENT (4775)

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writing

During suspension Respondent Chung shall not enter any pharmacy area or any portion of

the licensed premises of a wholesaler veterinary food-animal drug retailer or any other distributor

of drugs which is licensed by the board or any manufacturer or where dangerous drugs and

devices or controlled substances are maintained Respondent ChtmgBhallmiddotnotpractice pharmacy

nor do any act involving drug selection selection of stock manufacturing compounding

dispensing or patient consultation nor shall Respondent Chung 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 and controlled substances Respondent Chung shall not resume

practice until notified by the board

During suspension Respondent Chung shall not engage in any activity that requires the

professional judgment of a pharmacist Respondent Chung shall not direct or control any aspect

of the practice of pharmacy Respondent Chung shall not perform the duties of a pharmacy

technician or a designatedrepresentative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in arty licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwisespecified in thismiddot order

Failure to comply with this suspension shall be considered a violation of probation

20 No Ownership of Licensed Premises

Respondent Chung shall not own have any legal or beneficial interest in or serve as a

manager administrator member officer director trustee associate or partner of any business

firm pruinership or corporation currently or hereinafter licensed by the board Respondent

Chung shall sell or transfer any legal or beneficial interest in any entity licensed by the board

within ninety (90) days followiiig the effective date of this decision and shallimmediately

thereafter provide written proof thereof to the borumiddotd Failure to timely divest any legal or

beneficial interest(s) or provide documentation thereof shall be considered a violation of

probation

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STIPULATED SETTLEMENT (4775) I

r-----------------------------------------middot-middotmiddotmiddot-middotmiddot -

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21 Tolling of Suspension

During the period of suspension respondent shall not leave California for any period

exceeding ten (10) days regardless of purpose (including vacation) Any such absence in excess

ofthe (10) days d11ring suspension shall be considered a violation of probation Moreover any

absence from California during the period of suspension exceeding ten (1 0) days shall toll the

suspension ie the suspension shall be extended by one day for each day over ten (10) days

respondent is absent from California During any such period of tolling of suspension respondent

must nonetheless comply with all terms m1d conditions of probation

Respondent must notify the bomd in writing within ten (1 0) days of departure and must

further notify the board in writing within ten (1 0) days of return The f~ilure to provide such

notification(s) shall constitute a violation ofprobation Upon such departure m1d return

respondent shall not resume the practice ofpharmacy until notified by the board that the period of

middotsuspension has been satisfactorily completed

ACCEPTANCE

I have carefully read the above Stipulated Settlement and Disciplinary Order and have fully

discussed it with my attorney Benjamin Robert Margolis I understm1d the stipulation m1d the

effect it will have on my Original Pharmacist License I enter into this Stipulated Settlement and

Disciplinary Order voluntarily knowingly and intelligently and agree to be bound by the

Decision and Order of the Bommiddotd of Pharmacy

DATED I Anne Chon-Yin Chun ka A1me Chung

of

I have read m1d fully discussed with Respondent Chung the terms and conditions and other

matters contained in the above Stipulated2ettlet and Disciplinary Or~~middot~r__approve its form

and content middot ---~ -shy

DATED joj j1y ~ ~~middot-- bull J J~nj airul1Kobert Margolis

Lttorney for Respondent Chung

14 STIPULATED SETTLEMENT (4775)

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ENDORSEMENT

The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully

submitted for consideration by the Board of Pharmacy

Dated D -I - ~ Respectfully submitted

KAMALA D HARRIS Attorney General of California MARC D GREENBAUM Supervising Deputy Atton1ey General

GILLIAN E FRIEDMAN Deputy Attorney General Attorneys for Complainant

LA2013509837 51608369doc

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STIPULATED SETTLEMENT (4775)

Exhibit A

Accusation No 4775

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KAMALA D HARRlS A ttomey General of California MARC D GREENBAUM SuperVisingDeputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207 middot 300 So Spring Street Suite 1702

Los Angeles CA 90013 Telephone (213)897-2564 Facsimile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OF PHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Again~t

RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 PharmacyPermit No PHY 42331

ANNE CHON-YIN CHUNG 3 782 Moore Street Los Angeles CA 90066 Original Pharmacist License No RPH 40932

Respondents

Case No 4775

ACCUSATION

Complainant alleges

PARTIEsmiddot

1 Virginia Herold (Complainant) brings this Accusation solely in her official capacity

as the Executive Officer ofthe Board ofPharmacyDepartment of Consumer Affa)rs

2 On or about February 21 1997 the Board of Pharmacy issued Pharmacy Permit

Number PHY 42331 to Rite Aid 5429 located at 500 S Broadway Los Angeles California

90013-2302 (Respondent Rite Aid Pharmacy) The Pharmacy Permit was in full force and effect

Accusation

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at all times relevant to the charges brought herein and will expire on April 1 2014 unless

renewed

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932to Anne Chon-Yin Chu11g aka Anne Chung (Respondent Chung) The

Original Pharmacy License was in full force and effect at all times relevant to the charges brought

herein and will expire on January 312015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Respondent Rite Aiel Pharmacy

JURISDICTION

5 This Accusation is brought before the Board ofPharmacy (Board) Department of

Consumer Affairs under the authority onhe following laws All section references are to the

Business and Professions Code unless otherwise indicated

6 Section 4300 ofthe Code states

(a) Every license issued may be suspended or revoked

7 Section 4301 ofthe Code states

The board shall take action against any holder of a license who is guilty of unprofessional

conduct or whose license has been procured byfraud or misrepresentation or issued by mistake

Unprofessional conduct shall include but is not limited to any of the following

(a) Gross immorality

(b) Incompetence

(c) Gross negligence

(d) The clearly excessive furnishing of controiled substances in violation of subdivision (a)

of Section 11153 of the Health and Safety Code

(e) The cearly ~xces~iye furnishing of controlled substances in viqlation of subdivisiol (a)

of Section 111535 of the Health and Safety Code Factors to be considered in determining

whether the furnishing of controlled substances is clearly excessive shall include but not be

limited to the amount of controlled substances furnished the previous ordering pattern of the

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Accusation

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customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

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Accusation

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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Accusation

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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Accusation

(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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Accusation I

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

8 Accusation

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21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

9

Accusation

5

10

15

20

25

jmiddot

2

3

4

6

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9

11

12

13

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16

17

18

19

21

22

23 middot

24

26

27

28

middot

categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

10

Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

11

2

3

4

5

6

7

8

9

1o 11

12

13

middot14

15

16

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18

19

20

21

22

23

24

25

26

27

28

I

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

i 13I

I 14I I ll

16

17

18

19

21

22

23

24

26

27

28

a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

12

Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

2

3

4

5

6

7

8

9

1o 11

12

13

14 middot

15

16

17

18 middot

19

20

21

22

23

24

25

26

27

28

supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

l

2

3

4

5

6

7

8

9

1o 11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

f4

16

17

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21

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middot 23

24

26

27

28

e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

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16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

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11

12

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middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

14

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17

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19

21

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23

24

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27

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

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23 middot

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bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

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18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

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16

17

18

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21

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middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

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16 middot

17

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27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

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23 middot

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b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

1

2

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28

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

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e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

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3

4

5

6

7

8

9I j

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middot17

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middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

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y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

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f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

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middot 23

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

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m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

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Accusation

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e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

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4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

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Accusation

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-middot~-Jf)3~e_spo_rA~ntChl1ng V~rlcs for_or is ~mploye~ b)or tlyough (l Jh~JEaCY eJ11ployment

service Respondent Chung must notify her direct supervisor phannacist-in-charge and owner at

every entity ~icensed by the board of the terms arid conditions of the decision in case number

4775 in advance of the Respondent Chung commencing work at each licensed entity A record of

this notification mustbe provided to the board upon request

Furthemore within thiliy (30) days ofthe effective date of this decision and within fifteen

(15) days of Respondent Chung undertaking any Hew employment by or through a pharmacy

employment service Respondent Chlmg shall cause her direct supervisor with the pharmacy

employment service to report to the board in writing acknowledging that she has read the decision

in case number 4775 and the terms and conditions imposed thereby It shall be Respondent

Chlings respmisibility to ensure that her employer(s) andor supervisor(s) submit timely

acknowledgment(s) to the board

Failure to timely notify present or prospective employer(s) or to cause thatthose

employer(s) to submit timely acknowledgments to the board shall be considered a violation of

probation

Employment within the meaning of this provision shall include any full-time

pali-time temporary relief or pharmacy management service as a pharmacist or any

position for which a pharmacist license is a requirement or criterion for employment

whether the Respondent Chung is an employee independent contractor or volunteer

8 No Supervision oflnterns Serving as Pharmacist-in-Charge (PIC) Serving as Designated Representative-in-Charge or Serving as a Consultant

During the period of probation R~spondent Chlmg shall not supervise any intern

pharmacist be the pharmacist-in-charge or designated representative-in-charge of any entity

licensed by the board nor serve as a consultant unless otherwise specified in this order

Assumption of any such unauthorized supervision responsibilities shall middotbe considered a violation

of probation

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STIPULATED SETTLEMENT (4775)

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9 Reimbursement of Board Costs

As a condition precedent to successful completion of probation Respondent Chung shall

pay to the board its costs of investigation and prosecution in the amount of $826533

Respondent Chung shall make said payment on a payment plan approved by the board

There shall be no deviation from this schedule absent prior written middotapproval by the board or

its designee Failure to pay costs by the deadline(s) as directed shall be considered a violation of

probation

The filing of bankruptcy by Respondent Chung shall not relieve Respondent Chung of her

responsibility to reimburse the board its costs of investigation and prosecution

10 Probation Monitoring Costs

Respondent Chung shall pay any costs associated with probation monitoring as determined

by the board each and every year of probation Such costs shall be payable to the board on a

schedule as directed by the board or its designee Failure to pay such costs by the deadline(s) as

directed shall be considered a violation of probation

11 Status of License

Respondent Chung shall at all times while on probation maintain an active current license

with the boaid including any period during which suspension or probation is tolled Failure to

maintain an active current license shall be considered a violation of probation

IfRespondent ChLmg1s license expires or is cancelled by operation of law or otherwise at

any time during the period of probation including any extensions thereof due to tolling or

otherwise upon renewal or reapplication Respondent Chung1s license shall be subject to all terms

and conditions of this probation not previously satisfied

12 License Surrender While on ProbationSuspension

Following the effective date of this decision should Respondent Chung cease practice due

to retirement or health or be otherwise unable to satisfy the terms and conditions ofprobatiori

Respondent Chung maytender her license to the board for surrender The board or its designee

shall have the discretion whether to grant the request for surrender or take any other action it

deems appropriate and reasonable Upon formal acceptance of the surrender of the license

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STIPULATED SETTLEMENT ( 4 775)

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~~~E~-~d~n~__ ghu~will P-0 lltn~er be subject to ~e ~rrns an~ cndii_ol~ ofpro~a~ion This

surrender constitutes a record of discipline and shall become a part of the Respondent Chungs

license history with the board

Upon acceptance of the surrender Respondent Chung shall relinquish her pocket and wall

license to the board within ten ( 1 0) middotdays of notification by the board that the surrender is

accepted Respondent Chung may not reapply for any license from the board for three (3) years

from the effective date of the surrender Respondent Chung shall meet all requirements

applicable to the license sought as of the date the application for that license is submitted to the

board including any outstanding costs

13 Notification of a Change in N arne Residence Address Mailing Address or Employment middot

Respondent Chung shall notify the hoard in writing within ten (10) days of any change of

employment Said notification shall include the reasons for leaving the address of the new

~mployer the name ofthe supervise and owner and the work schedule ifknown Respondent

Chung shall further notify the board in writing within ten (1 0) days of a change in name

residence address mailing address or phone number

Failure to timely notify the board of any change in employer(s) name(s) address(es) or

phone number( s) shall be considered a violation of probation

14 Tolling of Probation

Except during periods of suspension Respondent Chung shall at all times while on

probation be employed as a pharmacist in California for a minimum of 40 hours per calendar

month Any month during which this minimum is not met shall toll the period of probation ie

the period ofpimiddotobation shall be extended by one month for each month during which this

minimum is not met During any such period oftolling of probation Respondent Chung must

nonetheless comply with all terms and conditions of probation

Should Respondent Chung regardless of residency for any reason (including vacation)

cease practicing as a pharmacist for a minimum of 40 hours per calendar month in California

Respondent Chung must notify the board in writing within ten (1 0) days of the cessation of

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STIPULATED SETTLEMENT ( 4775)

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practice and must further notify the board in writing within ten (1 0) days of the resumption of middotmiddot-middot -~ __ -- middot---middot- ~--

practice Any failure to provide such notification(s) shall be considered a violation of probation

It is a violation ofprobation for Respondent Chung1s probation to remain tolled pursuant to

the provisions of this condition for a total period counting consecutive and non-consecutive

months exceeding thirty-six (36) months

Cessation of practice means any cale~dar month during which Respondent

Chung is not practicing as a pharmacist for at least 40 hours as defined by Business

and Professions Code section 4000 et seq Resumption of practice means any

calendar month during which Respondent Chung is practicing as a pharmacist for at

least 40 hours as a pharmacist as defined by Business and Professions Code section

4000 et seq

15 Violation of Probation

If a Respondent Chung has not complied with any term or condition of probation the board

shall have continuing jurisdiction over Respondent Chung and probation shall automatically be

extended until all terms and conditions have been satisfied 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 that was stayed

If Respondent Chung violates probation in any respect the board after giving Respondent

Chung notice and an opportunity to be heard may revoke probation and carry out the disciplinary

order that was stayed Notice and opportunity to be heard are not required for those provisions

stating that a violation thereof may lead to automatic termination of the stay andor revocation of

the license If a petition to revoke probation or an accusation is filed against Respondent Chung

during probation the board shall have continuing jurisdiction and the period of probation shall be

automatically extended until the petition to revoke probation or accusation is heard and decided

16 Completion ofProbation

Upon written notice by the board or its designee indicating successful completion of

probation Respondent Chungs license will be fully restored

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STIPULATED SETTLEMENT (4775)

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17 Community Services Program middotmiddot--middot bull bullbull-bull _H_ bullI bull bullmiddotmiddotmiddotmiddotmiddot-~ bullmiddotbullbullo-middot bull bull~--middotmiddot-~---middotbull-bull~--bull-bullgtmiddotmiddot middotmiddotmiddotgtbull-bullmiddotbull -

Vilithin sixty (60) days of the effective date of this decision Respondent Chung shall submit

to the board or its designee for prior approval a community service program in which

Respondent Chung shall provide free health-care related services on a regular basis to a

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community or charitable facility or agency foimiddot at least 64 hours per year for each year of

probation Within thirty (30) days ofboard approval thereof Respondent Chung shall submit

documentation to the board demonstrating commencement of the community service program A

record ofthis notification must be provided to the board upon request Respondent Chung shall

report on progress with the community service program in the quarterly reports Failure to timely

submit con1inenceor comply witi1 the program shall be considered a violation of probation

18 Remedial Education

Yfithin sixty (60) days of the effective date ofthis decision Respondent Chung shall submit

to the board or its designee for prior approval an appropriate program of remedial education

related to dispensing of controlled substances corresponding responsibility and appropriate

controlled substance therapy The program of remedial education shall consist of at least ten (1 0)

units which shall be completed within the first three years of probation at Respondent Chung1s

own expense All remedial education shall be in addition to and shall not be credited toward

continuing education (CE) courses used for license renewal purposes

Failure to timely submit or complete the approved remedial education shall be considered a

violation of probation The period of probation will be automatically extended until such

remedial education is successfully completed and writte1i proof in a form acceptable to the board

is provided to the board or its designee

Following the completion of each course the board or its designee may require the

Respondent Chung at her own expense to take an approved examination to test the Respondent

Chung1s knowledge of the course If the Respondent Chung does not achieve a passing score on

the examination this failure shall be considered a violation ofprobation Any such examination

failure shall require Respondent Chung to take another course approved by the board in the same

subject area

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STIPULATED SETTLEMENT (4775) I

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19 Supervised Practi(e

During the period of probation Respondent Chung shall practice only under the supervision

of a licens~d pharmacist not on probation with the board Upon and after the effective date of this

decision Respondent Chung shall not practice pharmacy and her license shall be automatically

suspended until a supervisor is approved by the board or its designee The supervision shall be

as required by the board or its designee either

Continuous- At least 75 of a work week

Substantial - At least 50 of a wotk week

Partial- At least 25 of a work week

Daily Review- Supervisor1s review of probationer1S daily activities within 24 hours

Within thirty (30) days ofthe effective date of this decision Respondent Chung shall have

her supervisor submit notification to the board in writing stating that the supervisor has read the

decision iri case number 4775 and is familiar with the required level of supervision as determined

by the board or its designee It shall be the Respondent Chungs responsibility to ensme that her

employer(s) pharmacist-in-charge andor supervisor(s) submit timely acknowledgement(s) to the

board Failure to cause the direct supervisor and the pharmacist-in-charge to submit timely

acla1owledgements to the board shall be considered a violation of probation

If Respondent Chung changes employment it shall be the Respondent Chung s

responsibility to ensure that her employer(s) pharmacist-in-charge andor supervisor(s) submit

timely acknowledgement(s) to the board Respondent Chung shall have her new supervisor

within fifteen (15) days after employment commences submit notification to the board in writing

stating the direct supervisor and pharmacist-in-charge have read the decision in case number 4775

and is familiar with the level of supervision as determined by the board Respondent Chung shall

not practice pharmacy and her license shall be automatically suspended until the board or its

designee approves a new supervisor Failure to cause the direct supervisor and the phannacist-inshy

charge to submit timely acknowledgements to the board shall be considered a violation of

probation

Within ten (1 0) days of leaving employment Respondent Chung shall notify the board in

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STIPULATED SETTLEMENT (4775)

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writing

During suspension Respondent Chung shall not enter any pharmacy area or any portion of

the licensed premises of a wholesaler veterinary food-animal drug retailer or any other distributor

of drugs which is licensed by the board or any manufacturer or where dangerous drugs and

devices or controlled substances are maintained Respondent ChtmgBhallmiddotnotpractice pharmacy

nor do any act involving drug selection selection of stock manufacturing compounding

dispensing or patient consultation nor shall Respondent Chung 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 and controlled substances Respondent Chung shall not resume

practice until notified by the board

During suspension Respondent Chung shall not engage in any activity that requires the

professional judgment of a pharmacist Respondent Chung shall not direct or control any aspect

of the practice of pharmacy Respondent Chung shall not perform the duties of a pharmacy

technician or a designatedrepresentative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in arty licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwisespecified in thismiddot order

Failure to comply with this suspension shall be considered a violation of probation

20 No Ownership of Licensed Premises

Respondent Chung shall not own have any legal or beneficial interest in or serve as a

manager administrator member officer director trustee associate or partner of any business

firm pruinership or corporation currently or hereinafter licensed by the board Respondent

Chung shall sell or transfer any legal or beneficial interest in any entity licensed by the board

within ninety (90) days followiiig the effective date of this decision and shallimmediately

thereafter provide written proof thereof to the borumiddotd Failure to timely divest any legal or

beneficial interest(s) or provide documentation thereof shall be considered a violation of

probation

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STIPULATED SETTLEMENT (4775) I

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21 Tolling of Suspension

During the period of suspension respondent shall not leave California for any period

exceeding ten (10) days regardless of purpose (including vacation) Any such absence in excess

ofthe (10) days d11ring suspension shall be considered a violation of probation Moreover any

absence from California during the period of suspension exceeding ten (1 0) days shall toll the

suspension ie the suspension shall be extended by one day for each day over ten (10) days

respondent is absent from California During any such period of tolling of suspension respondent

must nonetheless comply with all terms m1d conditions of probation

Respondent must notify the bomd in writing within ten (1 0) days of departure and must

further notify the board in writing within ten (1 0) days of return The f~ilure to provide such

notification(s) shall constitute a violation ofprobation Upon such departure m1d return

respondent shall not resume the practice ofpharmacy until notified by the board that the period of

middotsuspension has been satisfactorily completed

ACCEPTANCE

I have carefully read the above Stipulated Settlement and Disciplinary Order and have fully

discussed it with my attorney Benjamin Robert Margolis I understm1d the stipulation m1d the

effect it will have on my Original Pharmacist License I enter into this Stipulated Settlement and

Disciplinary Order voluntarily knowingly and intelligently and agree to be bound by the

Decision and Order of the Bommiddotd of Pharmacy

DATED I Anne Chon-Yin Chun ka A1me Chung

of

I have read m1d fully discussed with Respondent Chung the terms and conditions and other

matters contained in the above Stipulated2ettlet and Disciplinary Or~~middot~r__approve its form

and content middot ---~ -shy

DATED joj j1y ~ ~~middot-- bull J J~nj airul1Kobert Margolis

Lttorney for Respondent Chung

14 STIPULATED SETTLEMENT (4775)

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ENDORSEMENT

The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully

submitted for consideration by the Board of Pharmacy

Dated D -I - ~ Respectfully submitted

KAMALA D HARRIS Attorney General of California MARC D GREENBAUM Supervising Deputy Atton1ey General

GILLIAN E FRIEDMAN Deputy Attorney General Attorneys for Complainant

LA2013509837 51608369doc

15

STIPULATED SETTLEMENT (4775)

Exhibit A

Accusation No 4775

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KAMALA D HARRlS A ttomey General of California MARC D GREENBAUM SuperVisingDeputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207 middot 300 So Spring Street Suite 1702

Los Angeles CA 90013 Telephone (213)897-2564 Facsimile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OF PHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Again~t

RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 PharmacyPermit No PHY 42331

ANNE CHON-YIN CHUNG 3 782 Moore Street Los Angeles CA 90066 Original Pharmacist License No RPH 40932

Respondents

Case No 4775

ACCUSATION

Complainant alleges

PARTIEsmiddot

1 Virginia Herold (Complainant) brings this Accusation solely in her official capacity

as the Executive Officer ofthe Board ofPharmacyDepartment of Consumer Affa)rs

2 On or about February 21 1997 the Board of Pharmacy issued Pharmacy Permit

Number PHY 42331 to Rite Aid 5429 located at 500 S Broadway Los Angeles California

90013-2302 (Respondent Rite Aid Pharmacy) The Pharmacy Permit was in full force and effect

Accusation

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at all times relevant to the charges brought herein and will expire on April 1 2014 unless

renewed

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932to Anne Chon-Yin Chu11g aka Anne Chung (Respondent Chung) The

Original Pharmacy License was in full force and effect at all times relevant to the charges brought

herein and will expire on January 312015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Respondent Rite Aiel Pharmacy

JURISDICTION

5 This Accusation is brought before the Board ofPharmacy (Board) Department of

Consumer Affairs under the authority onhe following laws All section references are to the

Business and Professions Code unless otherwise indicated

6 Section 4300 ofthe Code states

(a) Every license issued may be suspended or revoked

7 Section 4301 ofthe Code states

The board shall take action against any holder of a license who is guilty of unprofessional

conduct or whose license has been procured byfraud or misrepresentation or issued by mistake

Unprofessional conduct shall include but is not limited to any of the following

(a) Gross immorality

(b) Incompetence

(c) Gross negligence

(d) The clearly excessive furnishing of controiled substances in violation of subdivision (a)

of Section 11153 of the Health and Safety Code

(e) The cearly ~xces~iye furnishing of controlled substances in viqlation of subdivisiol (a)

of Section 111535 of the Health and Safety Code Factors to be considered in determining

whether the furnishing of controlled substances is clearly excessive shall include but not be

limited to the amount of controlled substances furnished the previous ordering pattern of the

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customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

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21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

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Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

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a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

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Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

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supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

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r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

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1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

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e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

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e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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

middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

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y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

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Accusation

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f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

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Accusation

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

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e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

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Accusation

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9 Reimbursement of Board Costs

As a condition precedent to successful completion of probation Respondent Chung shall

pay to the board its costs of investigation and prosecution in the amount of $826533

Respondent Chung shall make said payment on a payment plan approved by the board

There shall be no deviation from this schedule absent prior written middotapproval by the board or

its designee Failure to pay costs by the deadline(s) as directed shall be considered a violation of

probation

The filing of bankruptcy by Respondent Chung shall not relieve Respondent Chung of her

responsibility to reimburse the board its costs of investigation and prosecution

10 Probation Monitoring Costs

Respondent Chung shall pay any costs associated with probation monitoring as determined

by the board each and every year of probation Such costs shall be payable to the board on a

schedule as directed by the board or its designee Failure to pay such costs by the deadline(s) as

directed shall be considered a violation of probation

11 Status of License

Respondent Chung shall at all times while on probation maintain an active current license

with the boaid including any period during which suspension or probation is tolled Failure to

maintain an active current license shall be considered a violation of probation

IfRespondent ChLmg1s license expires or is cancelled by operation of law or otherwise at

any time during the period of probation including any extensions thereof due to tolling or

otherwise upon renewal or reapplication Respondent Chung1s license shall be subject to all terms

and conditions of this probation not previously satisfied

12 License Surrender While on ProbationSuspension

Following the effective date of this decision should Respondent Chung cease practice due

to retirement or health or be otherwise unable to satisfy the terms and conditions ofprobatiori

Respondent Chung maytender her license to the board for surrender The board or its designee

shall have the discretion whether to grant the request for surrender or take any other action it

deems appropriate and reasonable Upon formal acceptance of the surrender of the license

8

STIPULATED SETTLEMENT ( 4 775)

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~~~E~-~d~n~__ ghu~will P-0 lltn~er be subject to ~e ~rrns an~ cndii_ol~ ofpro~a~ion This

surrender constitutes a record of discipline and shall become a part of the Respondent Chungs

license history with the board

Upon acceptance of the surrender Respondent Chung shall relinquish her pocket and wall

license to the board within ten ( 1 0) middotdays of notification by the board that the surrender is

accepted Respondent Chung may not reapply for any license from the board for three (3) years

from the effective date of the surrender Respondent Chung shall meet all requirements

applicable to the license sought as of the date the application for that license is submitted to the

board including any outstanding costs

13 Notification of a Change in N arne Residence Address Mailing Address or Employment middot

Respondent Chung shall notify the hoard in writing within ten (10) days of any change of

employment Said notification shall include the reasons for leaving the address of the new

~mployer the name ofthe supervise and owner and the work schedule ifknown Respondent

Chung shall further notify the board in writing within ten (1 0) days of a change in name

residence address mailing address or phone number

Failure to timely notify the board of any change in employer(s) name(s) address(es) or

phone number( s) shall be considered a violation of probation

14 Tolling of Probation

Except during periods of suspension Respondent Chung shall at all times while on

probation be employed as a pharmacist in California for a minimum of 40 hours per calendar

month Any month during which this minimum is not met shall toll the period of probation ie

the period ofpimiddotobation shall be extended by one month for each month during which this

minimum is not met During any such period oftolling of probation Respondent Chung must

nonetheless comply with all terms and conditions of probation

Should Respondent Chung regardless of residency for any reason (including vacation)

cease practicing as a pharmacist for a minimum of 40 hours per calendar month in California

Respondent Chung must notify the board in writing within ten (1 0) days of the cessation of

9

STIPULATED SETTLEMENT ( 4775)

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practice and must further notify the board in writing within ten (1 0) days of the resumption of middotmiddot-middot -~ __ -- middot---middot- ~--

practice Any failure to provide such notification(s) shall be considered a violation of probation

It is a violation ofprobation for Respondent Chung1s probation to remain tolled pursuant to

the provisions of this condition for a total period counting consecutive and non-consecutive

months exceeding thirty-six (36) months

Cessation of practice means any cale~dar month during which Respondent

Chung is not practicing as a pharmacist for at least 40 hours as defined by Business

and Professions Code section 4000 et seq Resumption of practice means any

calendar month during which Respondent Chung is practicing as a pharmacist for at

least 40 hours as a pharmacist as defined by Business and Professions Code section

4000 et seq

15 Violation of Probation

If a Respondent Chung has not complied with any term or condition of probation the board

shall have continuing jurisdiction over Respondent Chung and probation shall automatically be

extended until all terms and conditions have been satisfied 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 that was stayed

If Respondent Chung violates probation in any respect the board after giving Respondent

Chung notice and an opportunity to be heard may revoke probation and carry out the disciplinary

order that was stayed Notice and opportunity to be heard are not required for those provisions

stating that a violation thereof may lead to automatic termination of the stay andor revocation of

the license If a petition to revoke probation or an accusation is filed against Respondent Chung

during probation the board shall have continuing jurisdiction and the period of probation shall be

automatically extended until the petition to revoke probation or accusation is heard and decided

16 Completion ofProbation

Upon written notice by the board or its designee indicating successful completion of

probation Respondent Chungs license will be fully restored

10

STIPULATED SETTLEMENT (4775)

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17 Community Services Program middotmiddot--middot bull bullbull-bull _H_ bullI bull bullmiddotmiddotmiddotmiddotmiddot-~ bullmiddotbullbullo-middot bull bull~--middotmiddot-~---middotbull-bull~--bull-bullgtmiddotmiddot middotmiddotmiddotgtbull-bullmiddotbull -

Vilithin sixty (60) days of the effective date of this decision Respondent Chung shall submit

to the board or its designee for prior approval a community service program in which

Respondent Chung shall provide free health-care related services on a regular basis to a

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community or charitable facility or agency foimiddot at least 64 hours per year for each year of

probation Within thirty (30) days ofboard approval thereof Respondent Chung shall submit

documentation to the board demonstrating commencement of the community service program A

record ofthis notification must be provided to the board upon request Respondent Chung shall

report on progress with the community service program in the quarterly reports Failure to timely

submit con1inenceor comply witi1 the program shall be considered a violation of probation

18 Remedial Education

Yfithin sixty (60) days of the effective date ofthis decision Respondent Chung shall submit

to the board or its designee for prior approval an appropriate program of remedial education

related to dispensing of controlled substances corresponding responsibility and appropriate

controlled substance therapy The program of remedial education shall consist of at least ten (1 0)

units which shall be completed within the first three years of probation at Respondent Chung1s

own expense All remedial education shall be in addition to and shall not be credited toward

continuing education (CE) courses used for license renewal purposes

Failure to timely submit or complete the approved remedial education shall be considered a

violation of probation The period of probation will be automatically extended until such

remedial education is successfully completed and writte1i proof in a form acceptable to the board

is provided to the board or its designee

Following the completion of each course the board or its designee may require the

Respondent Chung at her own expense to take an approved examination to test the Respondent

Chung1s knowledge of the course If the Respondent Chung does not achieve a passing score on

the examination this failure shall be considered a violation ofprobation Any such examination

failure shall require Respondent Chung to take another course approved by the board in the same

subject area

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STIPULATED SETTLEMENT (4775) I

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19 Supervised Practi(e

During the period of probation Respondent Chung shall practice only under the supervision

of a licens~d pharmacist not on probation with the board Upon and after the effective date of this

decision Respondent Chung shall not practice pharmacy and her license shall be automatically

suspended until a supervisor is approved by the board or its designee The supervision shall be

as required by the board or its designee either

Continuous- At least 75 of a work week

Substantial - At least 50 of a wotk week

Partial- At least 25 of a work week

Daily Review- Supervisor1s review of probationer1S daily activities within 24 hours

Within thirty (30) days ofthe effective date of this decision Respondent Chung shall have

her supervisor submit notification to the board in writing stating that the supervisor has read the

decision iri case number 4775 and is familiar with the required level of supervision as determined

by the board or its designee It shall be the Respondent Chungs responsibility to ensme that her

employer(s) pharmacist-in-charge andor supervisor(s) submit timely acknowledgement(s) to the

board Failure to cause the direct supervisor and the pharmacist-in-charge to submit timely

acla1owledgements to the board shall be considered a violation of probation

If Respondent Chung changes employment it shall be the Respondent Chung s

responsibility to ensure that her employer(s) pharmacist-in-charge andor supervisor(s) submit

timely acknowledgement(s) to the board Respondent Chung shall have her new supervisor

within fifteen (15) days after employment commences submit notification to the board in writing

stating the direct supervisor and pharmacist-in-charge have read the decision in case number 4775

and is familiar with the level of supervision as determined by the board Respondent Chung shall

not practice pharmacy and her license shall be automatically suspended until the board or its

designee approves a new supervisor Failure to cause the direct supervisor and the phannacist-inshy

charge to submit timely acknowledgements to the board shall be considered a violation of

probation

Within ten (1 0) days of leaving employment Respondent Chung shall notify the board in

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STIPULATED SETTLEMENT (4775)

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writing

During suspension Respondent Chung shall not enter any pharmacy area or any portion of

the licensed premises of a wholesaler veterinary food-animal drug retailer or any other distributor

of drugs which is licensed by the board or any manufacturer or where dangerous drugs and

devices or controlled substances are maintained Respondent ChtmgBhallmiddotnotpractice pharmacy

nor do any act involving drug selection selection of stock manufacturing compounding

dispensing or patient consultation nor shall Respondent Chung 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 and controlled substances Respondent Chung shall not resume

practice until notified by the board

During suspension Respondent Chung shall not engage in any activity that requires the

professional judgment of a pharmacist Respondent Chung shall not direct or control any aspect

of the practice of pharmacy Respondent Chung shall not perform the duties of a pharmacy

technician or a designatedrepresentative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in arty licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwisespecified in thismiddot order

Failure to comply with this suspension shall be considered a violation of probation

20 No Ownership of Licensed Premises

Respondent Chung shall not own have any legal or beneficial interest in or serve as a

manager administrator member officer director trustee associate or partner of any business

firm pruinership or corporation currently or hereinafter licensed by the board Respondent

Chung shall sell or transfer any legal or beneficial interest in any entity licensed by the board

within ninety (90) days followiiig the effective date of this decision and shallimmediately

thereafter provide written proof thereof to the borumiddotd Failure to timely divest any legal or

beneficial interest(s) or provide documentation thereof shall be considered a violation of

probation

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STIPULATED SETTLEMENT (4775) I

r-----------------------------------------middot-middotmiddotmiddot-middotmiddot -

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21 Tolling of Suspension

During the period of suspension respondent shall not leave California for any period

exceeding ten (10) days regardless of purpose (including vacation) Any such absence in excess

ofthe (10) days d11ring suspension shall be considered a violation of probation Moreover any

absence from California during the period of suspension exceeding ten (1 0) days shall toll the

suspension ie the suspension shall be extended by one day for each day over ten (10) days

respondent is absent from California During any such period of tolling of suspension respondent

must nonetheless comply with all terms m1d conditions of probation

Respondent must notify the bomd in writing within ten (1 0) days of departure and must

further notify the board in writing within ten (1 0) days of return The f~ilure to provide such

notification(s) shall constitute a violation ofprobation Upon such departure m1d return

respondent shall not resume the practice ofpharmacy until notified by the board that the period of

middotsuspension has been satisfactorily completed

ACCEPTANCE

I have carefully read the above Stipulated Settlement and Disciplinary Order and have fully

discussed it with my attorney Benjamin Robert Margolis I understm1d the stipulation m1d the

effect it will have on my Original Pharmacist License I enter into this Stipulated Settlement and

Disciplinary Order voluntarily knowingly and intelligently and agree to be bound by the

Decision and Order of the Bommiddotd of Pharmacy

DATED I Anne Chon-Yin Chun ka A1me Chung

of

I have read m1d fully discussed with Respondent Chung the terms and conditions and other

matters contained in the above Stipulated2ettlet and Disciplinary Or~~middot~r__approve its form

and content middot ---~ -shy

DATED joj j1y ~ ~~middot-- bull J J~nj airul1Kobert Margolis

Lttorney for Respondent Chung

14 STIPULATED SETTLEMENT (4775)

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ENDORSEMENT

The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully

submitted for consideration by the Board of Pharmacy

Dated D -I - ~ Respectfully submitted

KAMALA D HARRIS Attorney General of California MARC D GREENBAUM Supervising Deputy Atton1ey General

GILLIAN E FRIEDMAN Deputy Attorney General Attorneys for Complainant

LA2013509837 51608369doc

15

STIPULATED SETTLEMENT (4775)

Exhibit A

Accusation No 4775

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KAMALA D HARRlS A ttomey General of California MARC D GREENBAUM SuperVisingDeputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207 middot 300 So Spring Street Suite 1702

Los Angeles CA 90013 Telephone (213)897-2564 Facsimile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OF PHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Again~t

RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 PharmacyPermit No PHY 42331

ANNE CHON-YIN CHUNG 3 782 Moore Street Los Angeles CA 90066 Original Pharmacist License No RPH 40932

Respondents

Case No 4775

ACCUSATION

Complainant alleges

PARTIEsmiddot

1 Virginia Herold (Complainant) brings this Accusation solely in her official capacity

as the Executive Officer ofthe Board ofPharmacyDepartment of Consumer Affa)rs

2 On or about February 21 1997 the Board of Pharmacy issued Pharmacy Permit

Number PHY 42331 to Rite Aid 5429 located at 500 S Broadway Los Angeles California

90013-2302 (Respondent Rite Aid Pharmacy) The Pharmacy Permit was in full force and effect

Accusation

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at all times relevant to the charges brought herein and will expire on April 1 2014 unless

renewed

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932to Anne Chon-Yin Chu11g aka Anne Chung (Respondent Chung) The

Original Pharmacy License was in full force and effect at all times relevant to the charges brought

herein and will expire on January 312015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Respondent Rite Aiel Pharmacy

JURISDICTION

5 This Accusation is brought before the Board ofPharmacy (Board) Department of

Consumer Affairs under the authority onhe following laws All section references are to the

Business and Professions Code unless otherwise indicated

6 Section 4300 ofthe Code states

(a) Every license issued may be suspended or revoked

7 Section 4301 ofthe Code states

The board shall take action against any holder of a license who is guilty of unprofessional

conduct or whose license has been procured byfraud or misrepresentation or issued by mistake

Unprofessional conduct shall include but is not limited to any of the following

(a) Gross immorality

(b) Incompetence

(c) Gross negligence

(d) The clearly excessive furnishing of controiled substances in violation of subdivision (a)

of Section 11153 of the Health and Safety Code

(e) The cearly ~xces~iye furnishing of controlled substances in viqlation of subdivisiol (a)

of Section 111535 of the Health and Safety Code Factors to be considered in determining

whether the furnishing of controlled substances is clearly excessive shall include but not be

limited to the amount of controlled substances furnished the previous ordering pattern of the

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Accusation

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customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

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Accusation

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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Accusation

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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Accusation

(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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Accusation I

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

8 Accusation

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21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

10

Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

11

2

3

4

5

6

7

8

9

1o 11

12

13

middot14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

I

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

i 13I

I 14I I ll

16

17

18

19

21

22

23

24

26

27

28

a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

12

Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

2

3

4

5

6

7

8

9

1o 11

12

13

14 middot

15

16

17

18 middot

19

20

21

22

23

24

25

26

27

28

supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

l

2

3

4

5

6

7

8

9

1o 11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

f4

16

17

18

19

21

22

middot 23

24

26

27

28

e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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

middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

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26

27

28

I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25 I

26

27

28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

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25

26

27

28

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

10

15

20

25

2

3

4

6

7

8

9

11

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13

14

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18

19

21

22

23

24

26

27

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

11

12

13

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

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Accusation

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e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

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4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

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Accusation

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~~~E~-~d~n~__ ghu~will P-0 lltn~er be subject to ~e ~rrns an~ cndii_ol~ ofpro~a~ion This

surrender constitutes a record of discipline and shall become a part of the Respondent Chungs

license history with the board

Upon acceptance of the surrender Respondent Chung shall relinquish her pocket and wall

license to the board within ten ( 1 0) middotdays of notification by the board that the surrender is

accepted Respondent Chung may not reapply for any license from the board for three (3) years

from the effective date of the surrender Respondent Chung shall meet all requirements

applicable to the license sought as of the date the application for that license is submitted to the

board including any outstanding costs

13 Notification of a Change in N arne Residence Address Mailing Address or Employment middot

Respondent Chung shall notify the hoard in writing within ten (10) days of any change of

employment Said notification shall include the reasons for leaving the address of the new

~mployer the name ofthe supervise and owner and the work schedule ifknown Respondent

Chung shall further notify the board in writing within ten (1 0) days of a change in name

residence address mailing address or phone number

Failure to timely notify the board of any change in employer(s) name(s) address(es) or

phone number( s) shall be considered a violation of probation

14 Tolling of Probation

Except during periods of suspension Respondent Chung shall at all times while on

probation be employed as a pharmacist in California for a minimum of 40 hours per calendar

month Any month during which this minimum is not met shall toll the period of probation ie

the period ofpimiddotobation shall be extended by one month for each month during which this

minimum is not met During any such period oftolling of probation Respondent Chung must

nonetheless comply with all terms and conditions of probation

Should Respondent Chung regardless of residency for any reason (including vacation)

cease practicing as a pharmacist for a minimum of 40 hours per calendar month in California

Respondent Chung must notify the board in writing within ten (1 0) days of the cessation of

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STIPULATED SETTLEMENT ( 4775)

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practice and must further notify the board in writing within ten (1 0) days of the resumption of middotmiddot-middot -~ __ -- middot---middot- ~--

practice Any failure to provide such notification(s) shall be considered a violation of probation

It is a violation ofprobation for Respondent Chung1s probation to remain tolled pursuant to

the provisions of this condition for a total period counting consecutive and non-consecutive

months exceeding thirty-six (36) months

Cessation of practice means any cale~dar month during which Respondent

Chung is not practicing as a pharmacist for at least 40 hours as defined by Business

and Professions Code section 4000 et seq Resumption of practice means any

calendar month during which Respondent Chung is practicing as a pharmacist for at

least 40 hours as a pharmacist as defined by Business and Professions Code section

4000 et seq

15 Violation of Probation

If a Respondent Chung has not complied with any term or condition of probation the board

shall have continuing jurisdiction over Respondent Chung and probation shall automatically be

extended until all terms and conditions have been satisfied 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 that was stayed

If Respondent Chung violates probation in any respect the board after giving Respondent

Chung notice and an opportunity to be heard may revoke probation and carry out the disciplinary

order that was stayed Notice and opportunity to be heard are not required for those provisions

stating that a violation thereof may lead to automatic termination of the stay andor revocation of

the license If a petition to revoke probation or an accusation is filed against Respondent Chung

during probation the board shall have continuing jurisdiction and the period of probation shall be

automatically extended until the petition to revoke probation or accusation is heard and decided

16 Completion ofProbation

Upon written notice by the board or its designee indicating successful completion of

probation Respondent Chungs license will be fully restored

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STIPULATED SETTLEMENT (4775)

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17 Community Services Program middotmiddot--middot bull bullbull-bull _H_ bullI bull bullmiddotmiddotmiddotmiddotmiddot-~ bullmiddotbullbullo-middot bull bull~--middotmiddot-~---middotbull-bull~--bull-bullgtmiddotmiddot middotmiddotmiddotgtbull-bullmiddotbull -

Vilithin sixty (60) days of the effective date of this decision Respondent Chung shall submit

to the board or its designee for prior approval a community service program in which

Respondent Chung shall provide free health-care related services on a regular basis to a

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community or charitable facility or agency foimiddot at least 64 hours per year for each year of

probation Within thirty (30) days ofboard approval thereof Respondent Chung shall submit

documentation to the board demonstrating commencement of the community service program A

record ofthis notification must be provided to the board upon request Respondent Chung shall

report on progress with the community service program in the quarterly reports Failure to timely

submit con1inenceor comply witi1 the program shall be considered a violation of probation

18 Remedial Education

Yfithin sixty (60) days of the effective date ofthis decision Respondent Chung shall submit

to the board or its designee for prior approval an appropriate program of remedial education

related to dispensing of controlled substances corresponding responsibility and appropriate

controlled substance therapy The program of remedial education shall consist of at least ten (1 0)

units which shall be completed within the first three years of probation at Respondent Chung1s

own expense All remedial education shall be in addition to and shall not be credited toward

continuing education (CE) courses used for license renewal purposes

Failure to timely submit or complete the approved remedial education shall be considered a

violation of probation The period of probation will be automatically extended until such

remedial education is successfully completed and writte1i proof in a form acceptable to the board

is provided to the board or its designee

Following the completion of each course the board or its designee may require the

Respondent Chung at her own expense to take an approved examination to test the Respondent

Chung1s knowledge of the course If the Respondent Chung does not achieve a passing score on

the examination this failure shall be considered a violation ofprobation Any such examination

failure shall require Respondent Chung to take another course approved by the board in the same

subject area

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STIPULATED SETTLEMENT (4775) I

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19 Supervised Practi(e

During the period of probation Respondent Chung shall practice only under the supervision

of a licens~d pharmacist not on probation with the board Upon and after the effective date of this

decision Respondent Chung shall not practice pharmacy and her license shall be automatically

suspended until a supervisor is approved by the board or its designee The supervision shall be

as required by the board or its designee either

Continuous- At least 75 of a work week

Substantial - At least 50 of a wotk week

Partial- At least 25 of a work week

Daily Review- Supervisor1s review of probationer1S daily activities within 24 hours

Within thirty (30) days ofthe effective date of this decision Respondent Chung shall have

her supervisor submit notification to the board in writing stating that the supervisor has read the

decision iri case number 4775 and is familiar with the required level of supervision as determined

by the board or its designee It shall be the Respondent Chungs responsibility to ensme that her

employer(s) pharmacist-in-charge andor supervisor(s) submit timely acknowledgement(s) to the

board Failure to cause the direct supervisor and the pharmacist-in-charge to submit timely

acla1owledgements to the board shall be considered a violation of probation

If Respondent Chung changes employment it shall be the Respondent Chung s

responsibility to ensure that her employer(s) pharmacist-in-charge andor supervisor(s) submit

timely acknowledgement(s) to the board Respondent Chung shall have her new supervisor

within fifteen (15) days after employment commences submit notification to the board in writing

stating the direct supervisor and pharmacist-in-charge have read the decision in case number 4775

and is familiar with the level of supervision as determined by the board Respondent Chung shall

not practice pharmacy and her license shall be automatically suspended until the board or its

designee approves a new supervisor Failure to cause the direct supervisor and the phannacist-inshy

charge to submit timely acknowledgements to the board shall be considered a violation of

probation

Within ten (1 0) days of leaving employment Respondent Chung shall notify the board in

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STIPULATED SETTLEMENT (4775)

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writing

During suspension Respondent Chung shall not enter any pharmacy area or any portion of

the licensed premises of a wholesaler veterinary food-animal drug retailer or any other distributor

of drugs which is licensed by the board or any manufacturer or where dangerous drugs and

devices or controlled substances are maintained Respondent ChtmgBhallmiddotnotpractice pharmacy

nor do any act involving drug selection selection of stock manufacturing compounding

dispensing or patient consultation nor shall Respondent Chung 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 and controlled substances Respondent Chung shall not resume

practice until notified by the board

During suspension Respondent Chung shall not engage in any activity that requires the

professional judgment of a pharmacist Respondent Chung shall not direct or control any aspect

of the practice of pharmacy Respondent Chung shall not perform the duties of a pharmacy

technician or a designatedrepresentative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in arty licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwisespecified in thismiddot order

Failure to comply with this suspension shall be considered a violation of probation

20 No Ownership of Licensed Premises

Respondent Chung shall not own have any legal or beneficial interest in or serve as a

manager administrator member officer director trustee associate or partner of any business

firm pruinership or corporation currently or hereinafter licensed by the board Respondent

Chung shall sell or transfer any legal or beneficial interest in any entity licensed by the board

within ninety (90) days followiiig the effective date of this decision and shallimmediately

thereafter provide written proof thereof to the borumiddotd Failure to timely divest any legal or

beneficial interest(s) or provide documentation thereof shall be considered a violation of

probation

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STIPULATED SETTLEMENT (4775) I

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21 Tolling of Suspension

During the period of suspension respondent shall not leave California for any period

exceeding ten (10) days regardless of purpose (including vacation) Any such absence in excess

ofthe (10) days d11ring suspension shall be considered a violation of probation Moreover any

absence from California during the period of suspension exceeding ten (1 0) days shall toll the

suspension ie the suspension shall be extended by one day for each day over ten (10) days

respondent is absent from California During any such period of tolling of suspension respondent

must nonetheless comply with all terms m1d conditions of probation

Respondent must notify the bomd in writing within ten (1 0) days of departure and must

further notify the board in writing within ten (1 0) days of return The f~ilure to provide such

notification(s) shall constitute a violation ofprobation Upon such departure m1d return

respondent shall not resume the practice ofpharmacy until notified by the board that the period of

middotsuspension has been satisfactorily completed

ACCEPTANCE

I have carefully read the above Stipulated Settlement and Disciplinary Order and have fully

discussed it with my attorney Benjamin Robert Margolis I understm1d the stipulation m1d the

effect it will have on my Original Pharmacist License I enter into this Stipulated Settlement and

Disciplinary Order voluntarily knowingly and intelligently and agree to be bound by the

Decision and Order of the Bommiddotd of Pharmacy

DATED I Anne Chon-Yin Chun ka A1me Chung

of

I have read m1d fully discussed with Respondent Chung the terms and conditions and other

matters contained in the above Stipulated2ettlet and Disciplinary Or~~middot~r__approve its form

and content middot ---~ -shy

DATED joj j1y ~ ~~middot-- bull J J~nj airul1Kobert Margolis

Lttorney for Respondent Chung

14 STIPULATED SETTLEMENT (4775)

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ENDORSEMENT

The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully

submitted for consideration by the Board of Pharmacy

Dated D -I - ~ Respectfully submitted

KAMALA D HARRIS Attorney General of California MARC D GREENBAUM Supervising Deputy Atton1ey General

GILLIAN E FRIEDMAN Deputy Attorney General Attorneys for Complainant

LA2013509837 51608369doc

15

STIPULATED SETTLEMENT (4775)

Exhibit A

Accusation No 4775

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KAMALA D HARRlS A ttomey General of California MARC D GREENBAUM SuperVisingDeputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207 middot 300 So Spring Street Suite 1702

Los Angeles CA 90013 Telephone (213)897-2564 Facsimile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OF PHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Again~t

RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 PharmacyPermit No PHY 42331

ANNE CHON-YIN CHUNG 3 782 Moore Street Los Angeles CA 90066 Original Pharmacist License No RPH 40932

Respondents

Case No 4775

ACCUSATION

Complainant alleges

PARTIEsmiddot

1 Virginia Herold (Complainant) brings this Accusation solely in her official capacity

as the Executive Officer ofthe Board ofPharmacyDepartment of Consumer Affa)rs

2 On or about February 21 1997 the Board of Pharmacy issued Pharmacy Permit

Number PHY 42331 to Rite Aid 5429 located at 500 S Broadway Los Angeles California

90013-2302 (Respondent Rite Aid Pharmacy) The Pharmacy Permit was in full force and effect

Accusation

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at all times relevant to the charges brought herein and will expire on April 1 2014 unless

renewed

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932to Anne Chon-Yin Chu11g aka Anne Chung (Respondent Chung) The

Original Pharmacy License was in full force and effect at all times relevant to the charges brought

herein and will expire on January 312015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Respondent Rite Aiel Pharmacy

JURISDICTION

5 This Accusation is brought before the Board ofPharmacy (Board) Department of

Consumer Affairs under the authority onhe following laws All section references are to the

Business and Professions Code unless otherwise indicated

6 Section 4300 ofthe Code states

(a) Every license issued may be suspended or revoked

7 Section 4301 ofthe Code states

The board shall take action against any holder of a license who is guilty of unprofessional

conduct or whose license has been procured byfraud or misrepresentation or issued by mistake

Unprofessional conduct shall include but is not limited to any of the following

(a) Gross immorality

(b) Incompetence

(c) Gross negligence

(d) The clearly excessive furnishing of controiled substances in violation of subdivision (a)

of Section 11153 of the Health and Safety Code

(e) The cearly ~xces~iye furnishing of controlled substances in viqlation of subdivisiol (a)

of Section 111535 of the Health and Safety Code Factors to be considered in determining

whether the furnishing of controlled substances is clearly excessive shall include but not be

limited to the amount of controlled substances furnished the previous ordering pattern of the

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Accusation

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customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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Accusation

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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Accusation

(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

8 Accusation

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middot

21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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middot

categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

10

Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

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a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

12

Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

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supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

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r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

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e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

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e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

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Accusation

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middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

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Accusation

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bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

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l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

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middot 23

24

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I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

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17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

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11

middot12

13

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16 middot

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18

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28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

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5

6

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9

1o

II

12

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18

19

20

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23 middot

24

25

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28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

1

2

3

4

5

6

7

8

9

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12

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28

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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10

15

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25

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s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

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middot17

18

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25-middot

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middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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3

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

3

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I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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3

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

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f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

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Accusation

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

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Accusation

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e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

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4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

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practice and must further notify the board in writing within ten (1 0) days of the resumption of middotmiddot-middot -~ __ -- middot---middot- ~--

practice Any failure to provide such notification(s) shall be considered a violation of probation

It is a violation ofprobation for Respondent Chung1s probation to remain tolled pursuant to

the provisions of this condition for a total period counting consecutive and non-consecutive

months exceeding thirty-six (36) months

Cessation of practice means any cale~dar month during which Respondent

Chung is not practicing as a pharmacist for at least 40 hours as defined by Business

and Professions Code section 4000 et seq Resumption of practice means any

calendar month during which Respondent Chung is practicing as a pharmacist for at

least 40 hours as a pharmacist as defined by Business and Professions Code section

4000 et seq

15 Violation of Probation

If a Respondent Chung has not complied with any term or condition of probation the board

shall have continuing jurisdiction over Respondent Chung and probation shall automatically be

extended until all terms and conditions have been satisfied 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 that was stayed

If Respondent Chung violates probation in any respect the board after giving Respondent

Chung notice and an opportunity to be heard may revoke probation and carry out the disciplinary

order that was stayed Notice and opportunity to be heard are not required for those provisions

stating that a violation thereof may lead to automatic termination of the stay andor revocation of

the license If a petition to revoke probation or an accusation is filed against Respondent Chung

during probation the board shall have continuing jurisdiction and the period of probation shall be

automatically extended until the petition to revoke probation or accusation is heard and decided

16 Completion ofProbation

Upon written notice by the board or its designee indicating successful completion of

probation Respondent Chungs license will be fully restored

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STIPULATED SETTLEMENT (4775)

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17 Community Services Program middotmiddot--middot bull bullbull-bull _H_ bullI bull bullmiddotmiddotmiddotmiddotmiddot-~ bullmiddotbullbullo-middot bull bull~--middotmiddot-~---middotbull-bull~--bull-bullgtmiddotmiddot middotmiddotmiddotgtbull-bullmiddotbull -

Vilithin sixty (60) days of the effective date of this decision Respondent Chung shall submit

to the board or its designee for prior approval a community service program in which

Respondent Chung shall provide free health-care related services on a regular basis to a

middot

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community or charitable facility or agency foimiddot at least 64 hours per year for each year of

probation Within thirty (30) days ofboard approval thereof Respondent Chung shall submit

documentation to the board demonstrating commencement of the community service program A

record ofthis notification must be provided to the board upon request Respondent Chung shall

report on progress with the community service program in the quarterly reports Failure to timely

submit con1inenceor comply witi1 the program shall be considered a violation of probation

18 Remedial Education

Yfithin sixty (60) days of the effective date ofthis decision Respondent Chung shall submit

to the board or its designee for prior approval an appropriate program of remedial education

related to dispensing of controlled substances corresponding responsibility and appropriate

controlled substance therapy The program of remedial education shall consist of at least ten (1 0)

units which shall be completed within the first three years of probation at Respondent Chung1s

own expense All remedial education shall be in addition to and shall not be credited toward

continuing education (CE) courses used for license renewal purposes

Failure to timely submit or complete the approved remedial education shall be considered a

violation of probation The period of probation will be automatically extended until such

remedial education is successfully completed and writte1i proof in a form acceptable to the board

is provided to the board or its designee

Following the completion of each course the board or its designee may require the

Respondent Chung at her own expense to take an approved examination to test the Respondent

Chung1s knowledge of the course If the Respondent Chung does not achieve a passing score on

the examination this failure shall be considered a violation ofprobation Any such examination

failure shall require Respondent Chung to take another course approved by the board in the same

subject area

11

STIPULATED SETTLEMENT (4775) I

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19 Supervised Practi(e

During the period of probation Respondent Chung shall practice only under the supervision

of a licens~d pharmacist not on probation with the board Upon and after the effective date of this

decision Respondent Chung shall not practice pharmacy and her license shall be automatically

suspended until a supervisor is approved by the board or its designee The supervision shall be

as required by the board or its designee either

Continuous- At least 75 of a work week

Substantial - At least 50 of a wotk week

Partial- At least 25 of a work week

Daily Review- Supervisor1s review of probationer1S daily activities within 24 hours

Within thirty (30) days ofthe effective date of this decision Respondent Chung shall have

her supervisor submit notification to the board in writing stating that the supervisor has read the

decision iri case number 4775 and is familiar with the required level of supervision as determined

by the board or its designee It shall be the Respondent Chungs responsibility to ensme that her

employer(s) pharmacist-in-charge andor supervisor(s) submit timely acknowledgement(s) to the

board Failure to cause the direct supervisor and the pharmacist-in-charge to submit timely

acla1owledgements to the board shall be considered a violation of probation

If Respondent Chung changes employment it shall be the Respondent Chung s

responsibility to ensure that her employer(s) pharmacist-in-charge andor supervisor(s) submit

timely acknowledgement(s) to the board Respondent Chung shall have her new supervisor

within fifteen (15) days after employment commences submit notification to the board in writing

stating the direct supervisor and pharmacist-in-charge have read the decision in case number 4775

and is familiar with the level of supervision as determined by the board Respondent Chung shall

not practice pharmacy and her license shall be automatically suspended until the board or its

designee approves a new supervisor Failure to cause the direct supervisor and the phannacist-inshy

charge to submit timely acknowledgements to the board shall be considered a violation of

probation

Within ten (1 0) days of leaving employment Respondent Chung shall notify the board in

12

STIPULATED SETTLEMENT (4775)

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writing

During suspension Respondent Chung shall not enter any pharmacy area or any portion of

the licensed premises of a wholesaler veterinary food-animal drug retailer or any other distributor

of drugs which is licensed by the board or any manufacturer or where dangerous drugs and

devices or controlled substances are maintained Respondent ChtmgBhallmiddotnotpractice pharmacy

nor do any act involving drug selection selection of stock manufacturing compounding

dispensing or patient consultation nor shall Respondent Chung 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 and controlled substances Respondent Chung shall not resume

practice until notified by the board

During suspension Respondent Chung shall not engage in any activity that requires the

professional judgment of a pharmacist Respondent Chung shall not direct or control any aspect

of the practice of pharmacy Respondent Chung shall not perform the duties of a pharmacy

technician or a designatedrepresentative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in arty licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwisespecified in thismiddot order

Failure to comply with this suspension shall be considered a violation of probation

20 No Ownership of Licensed Premises

Respondent Chung shall not own have any legal or beneficial interest in or serve as a

manager administrator member officer director trustee associate or partner of any business

firm pruinership or corporation currently or hereinafter licensed by the board Respondent

Chung shall sell or transfer any legal or beneficial interest in any entity licensed by the board

within ninety (90) days followiiig the effective date of this decision and shallimmediately

thereafter provide written proof thereof to the borumiddotd Failure to timely divest any legal or

beneficial interest(s) or provide documentation thereof shall be considered a violation of

probation

13

STIPULATED SETTLEMENT (4775) I

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21 Tolling of Suspension

During the period of suspension respondent shall not leave California for any period

exceeding ten (10) days regardless of purpose (including vacation) Any such absence in excess

ofthe (10) days d11ring suspension shall be considered a violation of probation Moreover any

absence from California during the period of suspension exceeding ten (1 0) days shall toll the

suspension ie the suspension shall be extended by one day for each day over ten (10) days

respondent is absent from California During any such period of tolling of suspension respondent

must nonetheless comply with all terms m1d conditions of probation

Respondent must notify the bomd in writing within ten (1 0) days of departure and must

further notify the board in writing within ten (1 0) days of return The f~ilure to provide such

notification(s) shall constitute a violation ofprobation Upon such departure m1d return

respondent shall not resume the practice ofpharmacy until notified by the board that the period of

middotsuspension has been satisfactorily completed

ACCEPTANCE

I have carefully read the above Stipulated Settlement and Disciplinary Order and have fully

discussed it with my attorney Benjamin Robert Margolis I understm1d the stipulation m1d the

effect it will have on my Original Pharmacist License I enter into this Stipulated Settlement and

Disciplinary Order voluntarily knowingly and intelligently and agree to be bound by the

Decision and Order of the Bommiddotd of Pharmacy

DATED I Anne Chon-Yin Chun ka A1me Chung

of

I have read m1d fully discussed with Respondent Chung the terms and conditions and other

matters contained in the above Stipulated2ettlet and Disciplinary Or~~middot~r__approve its form

and content middot ---~ -shy

DATED joj j1y ~ ~~middot-- bull J J~nj airul1Kobert Margolis

Lttorney for Respondent Chung

14 STIPULATED SETTLEMENT (4775)

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ENDORSEMENT

The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully

submitted for consideration by the Board of Pharmacy

Dated D -I - ~ Respectfully submitted

KAMALA D HARRIS Attorney General of California MARC D GREENBAUM Supervising Deputy Atton1ey General

GILLIAN E FRIEDMAN Deputy Attorney General Attorneys for Complainant

LA2013509837 51608369doc

15

STIPULATED SETTLEMENT (4775)

Exhibit A

Accusation No 4775

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KAMALA D HARRlS A ttomey General of California MARC D GREENBAUM SuperVisingDeputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207 middot 300 So Spring Street Suite 1702

Los Angeles CA 90013 Telephone (213)897-2564 Facsimile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OF PHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Again~t

RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 PharmacyPermit No PHY 42331

ANNE CHON-YIN CHUNG 3 782 Moore Street Los Angeles CA 90066 Original Pharmacist License No RPH 40932

Respondents

Case No 4775

ACCUSATION

Complainant alleges

PARTIEsmiddot

1 Virginia Herold (Complainant) brings this Accusation solely in her official capacity

as the Executive Officer ofthe Board ofPharmacyDepartment of Consumer Affa)rs

2 On or about February 21 1997 the Board of Pharmacy issued Pharmacy Permit

Number PHY 42331 to Rite Aid 5429 located at 500 S Broadway Los Angeles California

90013-2302 (Respondent Rite Aid Pharmacy) The Pharmacy Permit was in full force and effect

Accusation

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at all times relevant to the charges brought herein and will expire on April 1 2014 unless

renewed

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932to Anne Chon-Yin Chu11g aka Anne Chung (Respondent Chung) The

Original Pharmacy License was in full force and effect at all times relevant to the charges brought

herein and will expire on January 312015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Respondent Rite Aiel Pharmacy

JURISDICTION

5 This Accusation is brought before the Board ofPharmacy (Board) Department of

Consumer Affairs under the authority onhe following laws All section references are to the

Business and Professions Code unless otherwise indicated

6 Section 4300 ofthe Code states

(a) Every license issued may be suspended or revoked

7 Section 4301 ofthe Code states

The board shall take action against any holder of a license who is guilty of unprofessional

conduct or whose license has been procured byfraud or misrepresentation or issued by mistake

Unprofessional conduct shall include but is not limited to any of the following

(a) Gross immorality

(b) Incompetence

(c) Gross negligence

(d) The clearly excessive furnishing of controiled substances in violation of subdivision (a)

of Section 11153 of the Health and Safety Code

(e) The cearly ~xces~iye furnishing of controlled substances in viqlation of subdivisiol (a)

of Section 111535 of the Health and Safety Code Factors to be considered in determining

whether the furnishing of controlled substances is clearly excessive shall include but not be

limited to the amount of controlled substances furnished the previous ordering pattern of the

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customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

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21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

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Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

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a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

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d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

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supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

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r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

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1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

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e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

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e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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

middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

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y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

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f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

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middot 23

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

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~~ bull

Ill

Ill

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e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

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17 Community Services Program middotmiddot--middot bull bullbull-bull _H_ bullI bull bullmiddotmiddotmiddotmiddotmiddot-~ bullmiddotbullbullo-middot bull bull~--middotmiddot-~---middotbull-bull~--bull-bullgtmiddotmiddot middotmiddotmiddotgtbull-bullmiddotbull -

Vilithin sixty (60) days of the effective date of this decision Respondent Chung shall submit

to the board or its designee for prior approval a community service program in which

Respondent Chung shall provide free health-care related services on a regular basis to a

middot

middot

community or charitable facility or agency foimiddot at least 64 hours per year for each year of

probation Within thirty (30) days ofboard approval thereof Respondent Chung shall submit

documentation to the board demonstrating commencement of the community service program A

record ofthis notification must be provided to the board upon request Respondent Chung shall

report on progress with the community service program in the quarterly reports Failure to timely

submit con1inenceor comply witi1 the program shall be considered a violation of probation

18 Remedial Education

Yfithin sixty (60) days of the effective date ofthis decision Respondent Chung shall submit

to the board or its designee for prior approval an appropriate program of remedial education

related to dispensing of controlled substances corresponding responsibility and appropriate

controlled substance therapy The program of remedial education shall consist of at least ten (1 0)

units which shall be completed within the first three years of probation at Respondent Chung1s

own expense All remedial education shall be in addition to and shall not be credited toward

continuing education (CE) courses used for license renewal purposes

Failure to timely submit or complete the approved remedial education shall be considered a

violation of probation The period of probation will be automatically extended until such

remedial education is successfully completed and writte1i proof in a form acceptable to the board

is provided to the board or its designee

Following the completion of each course the board or its designee may require the

Respondent Chung at her own expense to take an approved examination to test the Respondent

Chung1s knowledge of the course If the Respondent Chung does not achieve a passing score on

the examination this failure shall be considered a violation ofprobation Any such examination

failure shall require Respondent Chung to take another course approved by the board in the same

subject area

11

STIPULATED SETTLEMENT (4775) I

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19 Supervised Practi(e

During the period of probation Respondent Chung shall practice only under the supervision

of a licens~d pharmacist not on probation with the board Upon and after the effective date of this

decision Respondent Chung shall not practice pharmacy and her license shall be automatically

suspended until a supervisor is approved by the board or its designee The supervision shall be

as required by the board or its designee either

Continuous- At least 75 of a work week

Substantial - At least 50 of a wotk week

Partial- At least 25 of a work week

Daily Review- Supervisor1s review of probationer1S daily activities within 24 hours

Within thirty (30) days ofthe effective date of this decision Respondent Chung shall have

her supervisor submit notification to the board in writing stating that the supervisor has read the

decision iri case number 4775 and is familiar with the required level of supervision as determined

by the board or its designee It shall be the Respondent Chungs responsibility to ensme that her

employer(s) pharmacist-in-charge andor supervisor(s) submit timely acknowledgement(s) to the

board Failure to cause the direct supervisor and the pharmacist-in-charge to submit timely

acla1owledgements to the board shall be considered a violation of probation

If Respondent Chung changes employment it shall be the Respondent Chung s

responsibility to ensure that her employer(s) pharmacist-in-charge andor supervisor(s) submit

timely acknowledgement(s) to the board Respondent Chung shall have her new supervisor

within fifteen (15) days after employment commences submit notification to the board in writing

stating the direct supervisor and pharmacist-in-charge have read the decision in case number 4775

and is familiar with the level of supervision as determined by the board Respondent Chung shall

not practice pharmacy and her license shall be automatically suspended until the board or its

designee approves a new supervisor Failure to cause the direct supervisor and the phannacist-inshy

charge to submit timely acknowledgements to the board shall be considered a violation of

probation

Within ten (1 0) days of leaving employment Respondent Chung shall notify the board in

12

STIPULATED SETTLEMENT (4775)

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writing

During suspension Respondent Chung shall not enter any pharmacy area or any portion of

the licensed premises of a wholesaler veterinary food-animal drug retailer or any other distributor

of drugs which is licensed by the board or any manufacturer or where dangerous drugs and

devices or controlled substances are maintained Respondent ChtmgBhallmiddotnotpractice pharmacy

nor do any act involving drug selection selection of stock manufacturing compounding

dispensing or patient consultation nor shall Respondent Chung 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 and controlled substances Respondent Chung shall not resume

practice until notified by the board

During suspension Respondent Chung shall not engage in any activity that requires the

professional judgment of a pharmacist Respondent Chung shall not direct or control any aspect

of the practice of pharmacy Respondent Chung shall not perform the duties of a pharmacy

technician or a designatedrepresentative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in arty licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwisespecified in thismiddot order

Failure to comply with this suspension shall be considered a violation of probation

20 No Ownership of Licensed Premises

Respondent Chung shall not own have any legal or beneficial interest in or serve as a

manager administrator member officer director trustee associate or partner of any business

firm pruinership or corporation currently or hereinafter licensed by the board Respondent

Chung shall sell or transfer any legal or beneficial interest in any entity licensed by the board

within ninety (90) days followiiig the effective date of this decision and shallimmediately

thereafter provide written proof thereof to the borumiddotd Failure to timely divest any legal or

beneficial interest(s) or provide documentation thereof shall be considered a violation of

probation

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STIPULATED SETTLEMENT (4775) I

r-----------------------------------------middot-middotmiddotmiddot-middotmiddot -

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21 Tolling of Suspension

During the period of suspension respondent shall not leave California for any period

exceeding ten (10) days regardless of purpose (including vacation) Any such absence in excess

ofthe (10) days d11ring suspension shall be considered a violation of probation Moreover any

absence from California during the period of suspension exceeding ten (1 0) days shall toll the

suspension ie the suspension shall be extended by one day for each day over ten (10) days

respondent is absent from California During any such period of tolling of suspension respondent

must nonetheless comply with all terms m1d conditions of probation

Respondent must notify the bomd in writing within ten (1 0) days of departure and must

further notify the board in writing within ten (1 0) days of return The f~ilure to provide such

notification(s) shall constitute a violation ofprobation Upon such departure m1d return

respondent shall not resume the practice ofpharmacy until notified by the board that the period of

middotsuspension has been satisfactorily completed

ACCEPTANCE

I have carefully read the above Stipulated Settlement and Disciplinary Order and have fully

discussed it with my attorney Benjamin Robert Margolis I understm1d the stipulation m1d the

effect it will have on my Original Pharmacist License I enter into this Stipulated Settlement and

Disciplinary Order voluntarily knowingly and intelligently and agree to be bound by the

Decision and Order of the Bommiddotd of Pharmacy

DATED I Anne Chon-Yin Chun ka A1me Chung

of

I have read m1d fully discussed with Respondent Chung the terms and conditions and other

matters contained in the above Stipulated2ettlet and Disciplinary Or~~middot~r__approve its form

and content middot ---~ -shy

DATED joj j1y ~ ~~middot-- bull J J~nj airul1Kobert Margolis

Lttorney for Respondent Chung

14 STIPULATED SETTLEMENT (4775)

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ENDORSEMENT

The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully

submitted for consideration by the Board of Pharmacy

Dated D -I - ~ Respectfully submitted

KAMALA D HARRIS Attorney General of California MARC D GREENBAUM Supervising Deputy Atton1ey General

GILLIAN E FRIEDMAN Deputy Attorney General Attorneys for Complainant

LA2013509837 51608369doc

15

STIPULATED SETTLEMENT (4775)

Exhibit A

Accusation No 4775

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KAMALA D HARRlS A ttomey General of California MARC D GREENBAUM SuperVisingDeputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207 middot 300 So Spring Street Suite 1702

Los Angeles CA 90013 Telephone (213)897-2564 Facsimile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OF PHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Again~t

RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 PharmacyPermit No PHY 42331

ANNE CHON-YIN CHUNG 3 782 Moore Street Los Angeles CA 90066 Original Pharmacist License No RPH 40932

Respondents

Case No 4775

ACCUSATION

Complainant alleges

PARTIEsmiddot

1 Virginia Herold (Complainant) brings this Accusation solely in her official capacity

as the Executive Officer ofthe Board ofPharmacyDepartment of Consumer Affa)rs

2 On or about February 21 1997 the Board of Pharmacy issued Pharmacy Permit

Number PHY 42331 to Rite Aid 5429 located at 500 S Broadway Los Angeles California

90013-2302 (Respondent Rite Aid Pharmacy) The Pharmacy Permit was in full force and effect

Accusation

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at all times relevant to the charges brought herein and will expire on April 1 2014 unless

renewed

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932to Anne Chon-Yin Chu11g aka Anne Chung (Respondent Chung) The

Original Pharmacy License was in full force and effect at all times relevant to the charges brought

herein and will expire on January 312015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Respondent Rite Aiel Pharmacy

JURISDICTION

5 This Accusation is brought before the Board ofPharmacy (Board) Department of

Consumer Affairs under the authority onhe following laws All section references are to the

Business and Professions Code unless otherwise indicated

6 Section 4300 ofthe Code states

(a) Every license issued may be suspended or revoked

7 Section 4301 ofthe Code states

The board shall take action against any holder of a license who is guilty of unprofessional

conduct or whose license has been procured byfraud or misrepresentation or issued by mistake

Unprofessional conduct shall include but is not limited to any of the following

(a) Gross immorality

(b) Incompetence

(c) Gross negligence

(d) The clearly excessive furnishing of controiled substances in violation of subdivision (a)

of Section 11153 of the Health and Safety Code

(e) The cearly ~xces~iye furnishing of controlled substances in viqlation of subdivisiol (a)

of Section 111535 of the Health and Safety Code Factors to be considered in determining

whether the furnishing of controlled substances is clearly excessive shall include but not be

limited to the amount of controlled substances furnished the previous ordering pattern of the

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Accusation

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customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

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Accusation

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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Accusation

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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Accusation

(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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Accusation I

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

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21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

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Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

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a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

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d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

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supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

l

2

3

4

5

6

7

8

9

1o 11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

f4

16

17

18

19

21

22

middot 23

24

26

27

28

e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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3

4

5

6

7

8

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10

11

12

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

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I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

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3

4

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6

7 middot

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28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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3

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

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12

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14

15

16

17

18

19

ZO

21

22

middot23

24

25

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28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

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middot 23

24

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28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

10

15

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25

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-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

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bull

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

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5

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9

middot1 0

11

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middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

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19 Supervised Practi(e

During the period of probation Respondent Chung shall practice only under the supervision

of a licens~d pharmacist not on probation with the board Upon and after the effective date of this

decision Respondent Chung shall not practice pharmacy and her license shall be automatically

suspended until a supervisor is approved by the board or its designee The supervision shall be

as required by the board or its designee either

Continuous- At least 75 of a work week

Substantial - At least 50 of a wotk week

Partial- At least 25 of a work week

Daily Review- Supervisor1s review of probationer1S daily activities within 24 hours

Within thirty (30) days ofthe effective date of this decision Respondent Chung shall have

her supervisor submit notification to the board in writing stating that the supervisor has read the

decision iri case number 4775 and is familiar with the required level of supervision as determined

by the board or its designee It shall be the Respondent Chungs responsibility to ensme that her

employer(s) pharmacist-in-charge andor supervisor(s) submit timely acknowledgement(s) to the

board Failure to cause the direct supervisor and the pharmacist-in-charge to submit timely

acla1owledgements to the board shall be considered a violation of probation

If Respondent Chung changes employment it shall be the Respondent Chung s

responsibility to ensure that her employer(s) pharmacist-in-charge andor supervisor(s) submit

timely acknowledgement(s) to the board Respondent Chung shall have her new supervisor

within fifteen (15) days after employment commences submit notification to the board in writing

stating the direct supervisor and pharmacist-in-charge have read the decision in case number 4775

and is familiar with the level of supervision as determined by the board Respondent Chung shall

not practice pharmacy and her license shall be automatically suspended until the board or its

designee approves a new supervisor Failure to cause the direct supervisor and the phannacist-inshy

charge to submit timely acknowledgements to the board shall be considered a violation of

probation

Within ten (1 0) days of leaving employment Respondent Chung shall notify the board in

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STIPULATED SETTLEMENT (4775)

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writing

During suspension Respondent Chung shall not enter any pharmacy area or any portion of

the licensed premises of a wholesaler veterinary food-animal drug retailer or any other distributor

of drugs which is licensed by the board or any manufacturer or where dangerous drugs and

devices or controlled substances are maintained Respondent ChtmgBhallmiddotnotpractice pharmacy

nor do any act involving drug selection selection of stock manufacturing compounding

dispensing or patient consultation nor shall Respondent Chung 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 and controlled substances Respondent Chung shall not resume

practice until notified by the board

During suspension Respondent Chung shall not engage in any activity that requires the

professional judgment of a pharmacist Respondent Chung shall not direct or control any aspect

of the practice of pharmacy Respondent Chung shall not perform the duties of a pharmacy

technician or a designatedrepresentative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in arty licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwisespecified in thismiddot order

Failure to comply with this suspension shall be considered a violation of probation

20 No Ownership of Licensed Premises

Respondent Chung shall not own have any legal or beneficial interest in or serve as a

manager administrator member officer director trustee associate or partner of any business

firm pruinership or corporation currently or hereinafter licensed by the board Respondent

Chung shall sell or transfer any legal or beneficial interest in any entity licensed by the board

within ninety (90) days followiiig the effective date of this decision and shallimmediately

thereafter provide written proof thereof to the borumiddotd Failure to timely divest any legal or

beneficial interest(s) or provide documentation thereof shall be considered a violation of

probation

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STIPULATED SETTLEMENT (4775) I

r-----------------------------------------middot-middotmiddotmiddot-middotmiddot -

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21 Tolling of Suspension

During the period of suspension respondent shall not leave California for any period

exceeding ten (10) days regardless of purpose (including vacation) Any such absence in excess

ofthe (10) days d11ring suspension shall be considered a violation of probation Moreover any

absence from California during the period of suspension exceeding ten (1 0) days shall toll the

suspension ie the suspension shall be extended by one day for each day over ten (10) days

respondent is absent from California During any such period of tolling of suspension respondent

must nonetheless comply with all terms m1d conditions of probation

Respondent must notify the bomd in writing within ten (1 0) days of departure and must

further notify the board in writing within ten (1 0) days of return The f~ilure to provide such

notification(s) shall constitute a violation ofprobation Upon such departure m1d return

respondent shall not resume the practice ofpharmacy until notified by the board that the period of

middotsuspension has been satisfactorily completed

ACCEPTANCE

I have carefully read the above Stipulated Settlement and Disciplinary Order and have fully

discussed it with my attorney Benjamin Robert Margolis I understm1d the stipulation m1d the

effect it will have on my Original Pharmacist License I enter into this Stipulated Settlement and

Disciplinary Order voluntarily knowingly and intelligently and agree to be bound by the

Decision and Order of the Bommiddotd of Pharmacy

DATED I Anne Chon-Yin Chun ka A1me Chung

of

I have read m1d fully discussed with Respondent Chung the terms and conditions and other

matters contained in the above Stipulated2ettlet and Disciplinary Or~~middot~r__approve its form

and content middot ---~ -shy

DATED joj j1y ~ ~~middot-- bull J J~nj airul1Kobert Margolis

Lttorney for Respondent Chung

14 STIPULATED SETTLEMENT (4775)

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ENDORSEMENT

The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully

submitted for consideration by the Board of Pharmacy

Dated D -I - ~ Respectfully submitted

KAMALA D HARRIS Attorney General of California MARC D GREENBAUM Supervising Deputy Atton1ey General

GILLIAN E FRIEDMAN Deputy Attorney General Attorneys for Complainant

LA2013509837 51608369doc

15

STIPULATED SETTLEMENT (4775)

Exhibit A

Accusation No 4775

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KAMALA D HARRlS A ttomey General of California MARC D GREENBAUM SuperVisingDeputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207 middot 300 So Spring Street Suite 1702

Los Angeles CA 90013 Telephone (213)897-2564 Facsimile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OF PHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Again~t

RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 PharmacyPermit No PHY 42331

ANNE CHON-YIN CHUNG 3 782 Moore Street Los Angeles CA 90066 Original Pharmacist License No RPH 40932

Respondents

Case No 4775

ACCUSATION

Complainant alleges

PARTIEsmiddot

1 Virginia Herold (Complainant) brings this Accusation solely in her official capacity

as the Executive Officer ofthe Board ofPharmacyDepartment of Consumer Affa)rs

2 On or about February 21 1997 the Board of Pharmacy issued Pharmacy Permit

Number PHY 42331 to Rite Aid 5429 located at 500 S Broadway Los Angeles California

90013-2302 (Respondent Rite Aid Pharmacy) The Pharmacy Permit was in full force and effect

Accusation

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at all times relevant to the charges brought herein and will expire on April 1 2014 unless

renewed

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932to Anne Chon-Yin Chu11g aka Anne Chung (Respondent Chung) The

Original Pharmacy License was in full force and effect at all times relevant to the charges brought

herein and will expire on January 312015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Respondent Rite Aiel Pharmacy

JURISDICTION

5 This Accusation is brought before the Board ofPharmacy (Board) Department of

Consumer Affairs under the authority onhe following laws All section references are to the

Business and Professions Code unless otherwise indicated

6 Section 4300 ofthe Code states

(a) Every license issued may be suspended or revoked

7 Section 4301 ofthe Code states

The board shall take action against any holder of a license who is guilty of unprofessional

conduct or whose license has been procured byfraud or misrepresentation or issued by mistake

Unprofessional conduct shall include but is not limited to any of the following

(a) Gross immorality

(b) Incompetence

(c) Gross negligence

(d) The clearly excessive furnishing of controiled substances in violation of subdivision (a)

of Section 11153 of the Health and Safety Code

(e) The cearly ~xces~iye furnishing of controlled substances in viqlation of subdivisiol (a)

of Section 111535 of the Health and Safety Code Factors to be considered in determining

whether the furnishing of controlled substances is clearly excessive shall include but not be

limited to the amount of controlled substances furnished the previous ordering pattern of the

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Accusation

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customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

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Accusation

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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Accusation

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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Accusation

(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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Accusation I

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

8 Accusation

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21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

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Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

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a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

12

Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

2

3

4

5

6

7

8

9

1o 11

12

13

14 middot

15

16

17

18 middot

19

20

21

22

23

24

25

26

27

28

supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

l

2

3

4

5

6

7

8

9

1o 11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

f4

16

17

18

19

21

22

middot 23

24

26

27

28

e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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

middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

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

I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25 I

26

27

28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

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

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

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writing

During suspension Respondent Chung shall not enter any pharmacy area or any portion of

the licensed premises of a wholesaler veterinary food-animal drug retailer or any other distributor

of drugs which is licensed by the board or any manufacturer or where dangerous drugs and

devices or controlled substances are maintained Respondent ChtmgBhallmiddotnotpractice pharmacy

nor do any act involving drug selection selection of stock manufacturing compounding

dispensing or patient consultation nor shall Respondent Chung 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 and controlled substances Respondent Chung shall not resume

practice until notified by the board

During suspension Respondent Chung shall not engage in any activity that requires the

professional judgment of a pharmacist Respondent Chung shall not direct or control any aspect

of the practice of pharmacy Respondent Chung shall not perform the duties of a pharmacy

technician or a designatedrepresentative for any entity licensed by the board

Subject to the above restrictions Respondent Chung may continue to own or hold an

interest in arty licensed premises in which she holds an interest at the time this decision becomes

effective unless otherwisespecified in thismiddot order

Failure to comply with this suspension shall be considered a violation of probation

20 No Ownership of Licensed Premises

Respondent Chung shall not own have any legal or beneficial interest in or serve as a

manager administrator member officer director trustee associate or partner of any business

firm pruinership or corporation currently or hereinafter licensed by the board Respondent

Chung shall sell or transfer any legal or beneficial interest in any entity licensed by the board

within ninety (90) days followiiig the effective date of this decision and shallimmediately

thereafter provide written proof thereof to the borumiddotd Failure to timely divest any legal or

beneficial interest(s) or provide documentation thereof shall be considered a violation of

probation

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STIPULATED SETTLEMENT (4775) I

r-----------------------------------------middot-middotmiddotmiddot-middotmiddot -

~)

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21 Tolling of Suspension

During the period of suspension respondent shall not leave California for any period

exceeding ten (10) days regardless of purpose (including vacation) Any such absence in excess

ofthe (10) days d11ring suspension shall be considered a violation of probation Moreover any

absence from California during the period of suspension exceeding ten (1 0) days shall toll the

suspension ie the suspension shall be extended by one day for each day over ten (10) days

respondent is absent from California During any such period of tolling of suspension respondent

must nonetheless comply with all terms m1d conditions of probation

Respondent must notify the bomd in writing within ten (1 0) days of departure and must

further notify the board in writing within ten (1 0) days of return The f~ilure to provide such

notification(s) shall constitute a violation ofprobation Upon such departure m1d return

respondent shall not resume the practice ofpharmacy until notified by the board that the period of

middotsuspension has been satisfactorily completed

ACCEPTANCE

I have carefully read the above Stipulated Settlement and Disciplinary Order and have fully

discussed it with my attorney Benjamin Robert Margolis I understm1d the stipulation m1d the

effect it will have on my Original Pharmacist License I enter into this Stipulated Settlement and

Disciplinary Order voluntarily knowingly and intelligently and agree to be bound by the

Decision and Order of the Bommiddotd of Pharmacy

DATED I Anne Chon-Yin Chun ka A1me Chung

of

I have read m1d fully discussed with Respondent Chung the terms and conditions and other

matters contained in the above Stipulated2ettlet and Disciplinary Or~~middot~r__approve its form

and content middot ---~ -shy

DATED joj j1y ~ ~~middot-- bull J J~nj airul1Kobert Margolis

Lttorney for Respondent Chung

14 STIPULATED SETTLEMENT (4775)

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ENDORSEMENT

The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully

submitted for consideration by the Board of Pharmacy

Dated D -I - ~ Respectfully submitted

KAMALA D HARRIS Attorney General of California MARC D GREENBAUM Supervising Deputy Atton1ey General

GILLIAN E FRIEDMAN Deputy Attorney General Attorneys for Complainant

LA2013509837 51608369doc

15

STIPULATED SETTLEMENT (4775)

Exhibit A

Accusation No 4775

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KAMALA D HARRlS A ttomey General of California MARC D GREENBAUM SuperVisingDeputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207 middot 300 So Spring Street Suite 1702

Los Angeles CA 90013 Telephone (213)897-2564 Facsimile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OF PHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Again~t

RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 PharmacyPermit No PHY 42331

ANNE CHON-YIN CHUNG 3 782 Moore Street Los Angeles CA 90066 Original Pharmacist License No RPH 40932

Respondents

Case No 4775

ACCUSATION

Complainant alleges

PARTIEsmiddot

1 Virginia Herold (Complainant) brings this Accusation solely in her official capacity

as the Executive Officer ofthe Board ofPharmacyDepartment of Consumer Affa)rs

2 On or about February 21 1997 the Board of Pharmacy issued Pharmacy Permit

Number PHY 42331 to Rite Aid 5429 located at 500 S Broadway Los Angeles California

90013-2302 (Respondent Rite Aid Pharmacy) The Pharmacy Permit was in full force and effect

Accusation

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at all times relevant to the charges brought herein and will expire on April 1 2014 unless

renewed

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932to Anne Chon-Yin Chu11g aka Anne Chung (Respondent Chung) The

Original Pharmacy License was in full force and effect at all times relevant to the charges brought

herein and will expire on January 312015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Respondent Rite Aiel Pharmacy

JURISDICTION

5 This Accusation is brought before the Board ofPharmacy (Board) Department of

Consumer Affairs under the authority onhe following laws All section references are to the

Business and Professions Code unless otherwise indicated

6 Section 4300 ofthe Code states

(a) Every license issued may be suspended or revoked

7 Section 4301 ofthe Code states

The board shall take action against any holder of a license who is guilty of unprofessional

conduct or whose license has been procured byfraud or misrepresentation or issued by mistake

Unprofessional conduct shall include but is not limited to any of the following

(a) Gross immorality

(b) Incompetence

(c) Gross negligence

(d) The clearly excessive furnishing of controiled substances in violation of subdivision (a)

of Section 11153 of the Health and Safety Code

(e) The cearly ~xces~iye furnishing of controlled substances in viqlation of subdivisiol (a)

of Section 111535 of the Health and Safety Code Factors to be considered in determining

whether the furnishing of controlled substances is clearly excessive shall include but not be

limited to the amount of controlled substances furnished the previous ordering pattern of the

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Accusation

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customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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Accusation

(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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Accusation I

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

8 Accusation

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21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

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Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

11

2

3

4

5

6

7

8

9

1o 11

12

13

middot14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

I

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

i 13I

I 14I I ll

16

17

18

19

21

22

23

24

26

27

28

a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

12

Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

2

3

4

5

6

7

8

9

1o 11

12

13

14 middot

15

16

17

18 middot

19

20

21

22

23

24

25

26

27

28

supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

l

2

3

4

5

6

7

8

9

1o 11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

f4

16

17

18

19

21

22

middot 23

24

26

27

28

e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

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23

24

25

26

27

28

middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

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

I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25 I

26

27

28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

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23

24

25

26

27

28

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

2

3

4

5

6

7

8

9

10

11

12

13

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15

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17

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19

20

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28

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

10

15

20

25

2

3

4

6

7

8

9

11

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14

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19

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23

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26

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28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

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12

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17

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19

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28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

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Accusation

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e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

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4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

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Accusation

r-----------------------------------------middot-middotmiddotmiddot-middotmiddot -

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21 Tolling of Suspension

During the period of suspension respondent shall not leave California for any period

exceeding ten (10) days regardless of purpose (including vacation) Any such absence in excess

ofthe (10) days d11ring suspension shall be considered a violation of probation Moreover any

absence from California during the period of suspension exceeding ten (1 0) days shall toll the

suspension ie the suspension shall be extended by one day for each day over ten (10) days

respondent is absent from California During any such period of tolling of suspension respondent

must nonetheless comply with all terms m1d conditions of probation

Respondent must notify the bomd in writing within ten (1 0) days of departure and must

further notify the board in writing within ten (1 0) days of return The f~ilure to provide such

notification(s) shall constitute a violation ofprobation Upon such departure m1d return

respondent shall not resume the practice ofpharmacy until notified by the board that the period of

middotsuspension has been satisfactorily completed

ACCEPTANCE

I have carefully read the above Stipulated Settlement and Disciplinary Order and have fully

discussed it with my attorney Benjamin Robert Margolis I understm1d the stipulation m1d the

effect it will have on my Original Pharmacist License I enter into this Stipulated Settlement and

Disciplinary Order voluntarily knowingly and intelligently and agree to be bound by the

Decision and Order of the Bommiddotd of Pharmacy

DATED I Anne Chon-Yin Chun ka A1me Chung

of

I have read m1d fully discussed with Respondent Chung the terms and conditions and other

matters contained in the above Stipulated2ettlet and Disciplinary Or~~middot~r__approve its form

and content middot ---~ -shy

DATED joj j1y ~ ~~middot-- bull J J~nj airul1Kobert Margolis

Lttorney for Respondent Chung

14 STIPULATED SETTLEMENT (4775)

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ENDORSEMENT

The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully

submitted for consideration by the Board of Pharmacy

Dated D -I - ~ Respectfully submitted

KAMALA D HARRIS Attorney General of California MARC D GREENBAUM Supervising Deputy Atton1ey General

GILLIAN E FRIEDMAN Deputy Attorney General Attorneys for Complainant

LA2013509837 51608369doc

15

STIPULATED SETTLEMENT (4775)

Exhibit A

Accusation No 4775

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KAMALA D HARRlS A ttomey General of California MARC D GREENBAUM SuperVisingDeputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207 middot 300 So Spring Street Suite 1702

Los Angeles CA 90013 Telephone (213)897-2564 Facsimile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OF PHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Again~t

RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 PharmacyPermit No PHY 42331

ANNE CHON-YIN CHUNG 3 782 Moore Street Los Angeles CA 90066 Original Pharmacist License No RPH 40932

Respondents

Case No 4775

ACCUSATION

Complainant alleges

PARTIEsmiddot

1 Virginia Herold (Complainant) brings this Accusation solely in her official capacity

as the Executive Officer ofthe Board ofPharmacyDepartment of Consumer Affa)rs

2 On or about February 21 1997 the Board of Pharmacy issued Pharmacy Permit

Number PHY 42331 to Rite Aid 5429 located at 500 S Broadway Los Angeles California

90013-2302 (Respondent Rite Aid Pharmacy) The Pharmacy Permit was in full force and effect

Accusation

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at all times relevant to the charges brought herein and will expire on April 1 2014 unless

renewed

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932to Anne Chon-Yin Chu11g aka Anne Chung (Respondent Chung) The

Original Pharmacy License was in full force and effect at all times relevant to the charges brought

herein and will expire on January 312015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Respondent Rite Aiel Pharmacy

JURISDICTION

5 This Accusation is brought before the Board ofPharmacy (Board) Department of

Consumer Affairs under the authority onhe following laws All section references are to the

Business and Professions Code unless otherwise indicated

6 Section 4300 ofthe Code states

(a) Every license issued may be suspended or revoked

7 Section 4301 ofthe Code states

The board shall take action against any holder of a license who is guilty of unprofessional

conduct or whose license has been procured byfraud or misrepresentation or issued by mistake

Unprofessional conduct shall include but is not limited to any of the following

(a) Gross immorality

(b) Incompetence

(c) Gross negligence

(d) The clearly excessive furnishing of controiled substances in violation of subdivision (a)

of Section 11153 of the Health and Safety Code

(e) The cearly ~xces~iye furnishing of controlled substances in viqlation of subdivisiol (a)

of Section 111535 of the Health and Safety Code Factors to be considered in determining

whether the furnishing of controlled substances is clearly excessive shall include but not be

limited to the amount of controlled substances furnished the previous ordering pattern of the

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Accusation

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customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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Accusation

(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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Accusation I

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

8 Accusation

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21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

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Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

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11

12

i 13I

I 14I I ll

16

17

18

19

21

22

23

24

26

27

28

a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

12

Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

2

3

4

5

6

7

8

9

1o 11

12

13

14 middot

15

16

17

18 middot

19

20

21

22

23

24

25

26

27

28

supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

l

2

3

4

5

6

7

8

9

1o 11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

f4

16

17

18

19

21

22

middot 23

24

26

27

28

e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

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23

24

25

26

27

28

middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

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

I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25 I

26

27

28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

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25

26

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28

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

14

16

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18

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21

22

23

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26

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28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

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28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

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4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

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ENDORSEMENT

The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully

submitted for consideration by the Board of Pharmacy

Dated D -I - ~ Respectfully submitted

KAMALA D HARRIS Attorney General of California MARC D GREENBAUM Supervising Deputy Atton1ey General

GILLIAN E FRIEDMAN Deputy Attorney General Attorneys for Complainant

LA2013509837 51608369doc

15

STIPULATED SETTLEMENT (4775)

Exhibit A

Accusation No 4775

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KAMALA D HARRlS A ttomey General of California MARC D GREENBAUM SuperVisingDeputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207 middot 300 So Spring Street Suite 1702

Los Angeles CA 90013 Telephone (213)897-2564 Facsimile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OF PHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Again~t

RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 PharmacyPermit No PHY 42331

ANNE CHON-YIN CHUNG 3 782 Moore Street Los Angeles CA 90066 Original Pharmacist License No RPH 40932

Respondents

Case No 4775

ACCUSATION

Complainant alleges

PARTIEsmiddot

1 Virginia Herold (Complainant) brings this Accusation solely in her official capacity

as the Executive Officer ofthe Board ofPharmacyDepartment of Consumer Affa)rs

2 On or about February 21 1997 the Board of Pharmacy issued Pharmacy Permit

Number PHY 42331 to Rite Aid 5429 located at 500 S Broadway Los Angeles California

90013-2302 (Respondent Rite Aid Pharmacy) The Pharmacy Permit was in full force and effect

Accusation

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at all times relevant to the charges brought herein and will expire on April 1 2014 unless

renewed

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932to Anne Chon-Yin Chu11g aka Anne Chung (Respondent Chung) The

Original Pharmacy License was in full force and effect at all times relevant to the charges brought

herein and will expire on January 312015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Respondent Rite Aiel Pharmacy

JURISDICTION

5 This Accusation is brought before the Board ofPharmacy (Board) Department of

Consumer Affairs under the authority onhe following laws All section references are to the

Business and Professions Code unless otherwise indicated

6 Section 4300 ofthe Code states

(a) Every license issued may be suspended or revoked

7 Section 4301 ofthe Code states

The board shall take action against any holder of a license who is guilty of unprofessional

conduct or whose license has been procured byfraud or misrepresentation or issued by mistake

Unprofessional conduct shall include but is not limited to any of the following

(a) Gross immorality

(b) Incompetence

(c) Gross negligence

(d) The clearly excessive furnishing of controiled substances in violation of subdivision (a)

of Section 11153 of the Health and Safety Code

(e) The cearly ~xces~iye furnishing of controlled substances in viqlation of subdivisiol (a)

of Section 111535 of the Health and Safety Code Factors to be considered in determining

whether the furnishing of controlled substances is clearly excessive shall include but not be

limited to the amount of controlled substances furnished the previous ordering pattern of the

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customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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Accusation

(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

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21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

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Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

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a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

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d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

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supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

l

2

3

4

5

6

7

8

9

1o 11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

f4

16

17

18

19

21

22

middot 23

24

26

27

28

e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

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9I j

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middot17

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middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

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y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

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f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

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middot 23

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

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middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

Exhibit A

Accusation No 4775

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KAMALA D HARRlS A ttomey General of California MARC D GREENBAUM SuperVisingDeputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207 middot 300 So Spring Street Suite 1702

Los Angeles CA 90013 Telephone (213)897-2564 Facsimile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OF PHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Again~t

RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 PharmacyPermit No PHY 42331

ANNE CHON-YIN CHUNG 3 782 Moore Street Los Angeles CA 90066 Original Pharmacist License No RPH 40932

Respondents

Case No 4775

ACCUSATION

Complainant alleges

PARTIEsmiddot

1 Virginia Herold (Complainant) brings this Accusation solely in her official capacity

as the Executive Officer ofthe Board ofPharmacyDepartment of Consumer Affa)rs

2 On or about February 21 1997 the Board of Pharmacy issued Pharmacy Permit

Number PHY 42331 to Rite Aid 5429 located at 500 S Broadway Los Angeles California

90013-2302 (Respondent Rite Aid Pharmacy) The Pharmacy Permit was in full force and effect

Accusation

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at all times relevant to the charges brought herein and will expire on April 1 2014 unless

renewed

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932to Anne Chon-Yin Chu11g aka Anne Chung (Respondent Chung) The

Original Pharmacy License was in full force and effect at all times relevant to the charges brought

herein and will expire on January 312015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Respondent Rite Aiel Pharmacy

JURISDICTION

5 This Accusation is brought before the Board ofPharmacy (Board) Department of

Consumer Affairs under the authority onhe following laws All section references are to the

Business and Professions Code unless otherwise indicated

6 Section 4300 ofthe Code states

(a) Every license issued may be suspended or revoked

7 Section 4301 ofthe Code states

The board shall take action against any holder of a license who is guilty of unprofessional

conduct or whose license has been procured byfraud or misrepresentation or issued by mistake

Unprofessional conduct shall include but is not limited to any of the following

(a) Gross immorality

(b) Incompetence

(c) Gross negligence

(d) The clearly excessive furnishing of controiled substances in violation of subdivision (a)

of Section 11153 of the Health and Safety Code

(e) The cearly ~xces~iye furnishing of controlled substances in viqlation of subdivisiol (a)

of Section 111535 of the Health and Safety Code Factors to be considered in determining

whether the furnishing of controlled substances is clearly excessive shall include but not be

limited to the amount of controlled substances furnished the previous ordering pattern of the

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customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

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21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

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Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

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a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

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d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

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supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

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r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

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1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

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e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

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y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

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f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

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middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

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KAMALA D HARRlS A ttomey General of California MARC D GREENBAUM SuperVisingDeputy Attorney General GILLIAN E FRIEDMAN Deputy Attorney General State Bar No 169207 middot 300 So Spring Street Suite 1702

Los Angeles CA 90013 Telephone (213)897-2564 Facsimile (213) 897-2804

Attorneys for Complainant

BEFORE THE BOARD OF PHARMACY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Again~t

RITE AID PHARMACY 5429 ANNE CHUNG Pharmacist in Charge 500 S Broadway Los Angeles CA 90013 PharmacyPermit No PHY 42331

ANNE CHON-YIN CHUNG 3 782 Moore Street Los Angeles CA 90066 Original Pharmacist License No RPH 40932

Respondents

Case No 4775

ACCUSATION

Complainant alleges

PARTIEsmiddot

1 Virginia Herold (Complainant) brings this Accusation solely in her official capacity

as the Executive Officer ofthe Board ofPharmacyDepartment of Consumer Affa)rs

2 On or about February 21 1997 the Board of Pharmacy issued Pharmacy Permit

Number PHY 42331 to Rite Aid 5429 located at 500 S Broadway Los Angeles California

90013-2302 (Respondent Rite Aid Pharmacy) The Pharmacy Permit was in full force and effect

Accusation

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at all times relevant to the charges brought herein and will expire on April 1 2014 unless

renewed

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932to Anne Chon-Yin Chu11g aka Anne Chung (Respondent Chung) The

Original Pharmacy License was in full force and effect at all times relevant to the charges brought

herein and will expire on January 312015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Respondent Rite Aiel Pharmacy

JURISDICTION

5 This Accusation is brought before the Board ofPharmacy (Board) Department of

Consumer Affairs under the authority onhe following laws All section references are to the

Business and Professions Code unless otherwise indicated

6 Section 4300 ofthe Code states

(a) Every license issued may be suspended or revoked

7 Section 4301 ofthe Code states

The board shall take action against any holder of a license who is guilty of unprofessional

conduct or whose license has been procured byfraud or misrepresentation or issued by mistake

Unprofessional conduct shall include but is not limited to any of the following

(a) Gross immorality

(b) Incompetence

(c) Gross negligence

(d) The clearly excessive furnishing of controiled substances in violation of subdivision (a)

of Section 11153 of the Health and Safety Code

(e) The cearly ~xces~iye furnishing of controlled substances in viqlation of subdivisiol (a)

of Section 111535 of the Health and Safety Code Factors to be considered in determining

whether the furnishing of controlled substances is clearly excessive shall include but not be

limited to the amount of controlled substances furnished the previous ordering pattern of the

2

Accusation

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customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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Accusation

(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

8 Accusation

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middot

21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

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Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

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a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

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Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

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supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

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r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

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1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

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Accusation

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e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

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e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

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s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

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24

25

26

27

28

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

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21

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24

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28

middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

3

4

5

6

7

8

9

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16

17

18

19

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22

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24

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28

I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25 I

26

27

28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

2

3

4

5

6

7

8

9

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11

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14

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26

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28

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

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

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

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20

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23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

5

6

7

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9

10

11

12

13

14

15

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18

19

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21

22

25

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28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

5

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15

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25

2

3

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6

7

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at all times relevant to the charges brought herein and will expire on April 1 2014 unless

renewed

3 On or about May 13 1987 the Board of Pharmacy issued Original Pharmacist

License No RPH 40932to Anne Chon-Yin Chu11g aka Anne Chung (Respondent Chung) The

Original Pharmacy License was in full force and effect at all times relevant to the charges brought

herein and will expire on January 312015 unless renewed

4 On or about April 9 2000 Respondent Chung became the Pharmacist in Charge for

Respondent Rite Aiel Pharmacy

JURISDICTION

5 This Accusation is brought before the Board ofPharmacy (Board) Department of

Consumer Affairs under the authority onhe following laws All section references are to the

Business and Professions Code unless otherwise indicated

6 Section 4300 ofthe Code states

(a) Every license issued may be suspended or revoked

7 Section 4301 ofthe Code states

The board shall take action against any holder of a license who is guilty of unprofessional

conduct or whose license has been procured byfraud or misrepresentation or issued by mistake

Unprofessional conduct shall include but is not limited to any of the following

(a) Gross immorality

(b) Incompetence

(c) Gross negligence

(d) The clearly excessive furnishing of controiled substances in violation of subdivision (a)

of Section 11153 of the Health and Safety Code

(e) The cearly ~xces~iye furnishing of controlled substances in viqlation of subdivisiol (a)

of Section 111535 of the Health and Safety Code Factors to be considered in determining

whether the furnishing of controlled substances is clearly excessive shall include but not be

limited to the amount of controlled substances furnished the previous ordering pattern of the

2

Accusation

middot

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23

24

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27

28

customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

3

Accusation

i I I I

1 middot

2

3

4

5

6

7

8

9

10

11

12

13

14

15

1 6

17

18

19

21

20

22

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24

25

26

middot27

28

have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

4

Accusation

i

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

2D

21

22

23

middot 24

25

26

27

28

Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

8 Accusation

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21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

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Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

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a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

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Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

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supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

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r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

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1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

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e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

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e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

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s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

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Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

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25

2

3

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middot 7

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middot26

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l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

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25

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middot 23

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I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

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20

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24

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26

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17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

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16 middot

17

18

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28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

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5

6

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9

1o

II

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19

20

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23 middot

24

25

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b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

1

2

3

4

5

6

7

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28

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

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18

19

20

21

22

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25

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27

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e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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10

15

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25

2

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6

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s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

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middot17

18

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25-middot

26

27

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middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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2

3

4

5

6

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

3

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I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

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25 I

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

2

3

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

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f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

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middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

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customer (including size and frequency of orders) the type and size of the customer and where

and to whom the customer distributes its product

(f) The commission of any act involving moral turpitude dishonesty fraud deceit or

corruption whether the act is committed in the course of relations as a licensee or otherwise and

whether the act is a felony cir misdemeanor or not

(g) Knowingly making or signing any certificate or other docume~t that falsely represents

the existence or nonexistence of a state of facts

(h) The administering to oneself of any controlled substance or the use of any dangerous

drug or of alcoholic beverages to the extent or in a manner as to be dangerous or injurious to middot

oneself to a person holding a license under this chapter or to any other person or to the pubJic or

to the extent that the use impairs the ability of the person to conduct with safety to the public the

practice authorized by the license

middot (i) Except as otherwise authorized middotby law knowingly selling furnishing giving away or

administering or offering to sell furnish give away or administer any controlled substance to an

addict

U) The violation of any ofthe statutes of this state or any other state or of the United

States regulating controlled substances and dangerous drugs

(o) Violating or attempting to violate directly or indirectly or assisting in or abetting the

violation of or conspiring to violate any provision or term of this chapter or of the applicable

federal and state laws and regulations governing pharmacy including reg11lations established by

the board or by any other state or federal regulatory agency

(p) Actions or conductthat would have warranted denial ofa license

(q) Engaging in any conduct that subverts or attempts to subvert an investigation ofthe

board

(r) The selling trading transferring or furnishing of drugs obtained pursuant to Section

256b ofTitle 42 ofthe United States Code to any person a licensee knows or reasonably should

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Accusation

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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I I

pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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Accusation

(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

8 Accusation

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middot

21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

9

Accusation

5

10

15

20

25

jmiddot

2

3

4

6

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11

12

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16

17

18

19

21

22

23 middot

24

26

27

28

middot

categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

10

Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

11

2

3

4

5

6

7

8

9

1o 11

12

13

middot14

15

16

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18

19

20

21

22

23

24

25

26

27

28

I

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

i 13I

I 14I I ll

16

17

18

19

21

22

23

24

26

27

28

a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

12

Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

2

3

4

5

6

7

8

9

1o 11

12

13

14 middot

15

16

17

18 middot

19

20

21

22

23

24

25

26

27

28

supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

l

2

3

4

5

6

7

8

9

1o 11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

f4

16

17

18

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21

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middot 23

24

26

27

28

e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

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16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

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middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

14

16

17

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19

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23

24

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27

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

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23 middot

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bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

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18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

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6

7

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9

II

12

13

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middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

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16 middot

17

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28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

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23 middot

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b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

1

2

3

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28

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

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1 0

11

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e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

5

10

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s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

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middot17

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middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

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I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

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middot23

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f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

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middot 23

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

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m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

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Accusation

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e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

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4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

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have known not to be a patiYnt of acovered entity as defined in paragraph ( 4) of subsection (a)

of Section 256b ofTitle 42 ofthe United States Coqe

11 (s) The clearly excessive furnishing of dangerous drugs by a wholesaler to a pharmacy that

primarily or solely dispenses prescription drugs to patients of long-term care facilities Factors tomiddot

be considered in determining whether the furnishing of dangerous drugs is clearly excessive shall

include but not be limited to the amount of dangerous drugs furnished to a pharmacy that

primfrily or solely dispenses prescription drugs to patients oflong-term care faciiitielts the

previous ordering pattern of the pharmcy and the general patient population to whqm the

pharmacy distributes the dangerous drugs That a wholes~ler has estaqlished and employs a

tracking system that complies with the requirements of subdivision (b) of Section 4164 shall be

considered in determining whether there has been a violation ofthis subdivision This provision

shali not be interpretYd to requjre a wholesaler to obtairi personal meqical information or be

authorized to permit a whqlesaler to have access to personal mcentdical information except as

otherwise authorized by Section 56 and following of the Civil Code 11

8 Section 4059 6fthe Code states in pertinent part that a person may not furnish any

dangerous drug except upon the prescription of a pHysician d~ntist podiatrist optometrist middot

veterinarian or naturopathic doctor pursuant to Section 36407 A person Tiay not furnisj1 any

dangerous device except upon the prescription of a physician dentist poltiiatrist optometrist

veterinaritn or naturopathic doctor pursuant to Stltction 36407

9 Section 4081 of tile Coqe states

11 ( a) All records -of rhlinufactute and of Sale acquisition or dispoition of qang~rqus drugs

or dang~rpus deviq~s sh~ll pe at all times during business hours open to inspectiqri lJy avthorized

officers ofthe law and shall be pre~erved for at leastthree yearsmiddotfrom the date ofwakiJlg A

current inventory shall be kept by every mariufaqturer whcilesa~er pharmacy veterinary

food-animal drug r~taH~r physician dentist podiatrist veterinarian laboratory c)jnic hospital

institution or establishment holding a currently valid and unrevoked certificate license permit

registration or exemption under Division 2 (commencing with Section 1200) ofthe Health and

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

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21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

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Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

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a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

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Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

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supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

l

2

3

4

5

6

7

8

9

1o 11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

f4

16

17

18

19

21

22

middot 23

24

26

27

28

e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

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28

middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

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I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

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25 I

26

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28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

2

3

4

5

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

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middot 23

24

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28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

2

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

10

15

20

25

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-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

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25

bull

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

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5

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9

middot1 0

11

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28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

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23

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

i

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2D

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middot 24

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Safety Code or under Part 4 (commencing with Section 16000) of Division 9 of the Welfare and

Institutions Code who maintains a stock of dangerous drugs or dangerous devices middot

(b) The owner officer and partner of any pharmacy wholesaler or veterinary food-animal

drug retailer shall be jointly responsible with the pharmacist-in-charge or representative~in-

charge for maintaining the records and inventory described in this section

(c) The pharmacist-in-charge orrepresentative-in-charge shall not be criminally

responsible for acts of the owner offic~r partner or employee that violate this section and of

which the pharmacist-in-charge or representative-in-charge had no knowledge or in which he or

she did not knowingly participate

10 Section 4324 ofthe Code states

(a) Every person who signs the name of another or of a fictitious person or falsely makes

alters forges titters publishes passes or attempts to pass as genuine any prescription for any

drugs is guilty of forgery and upon conviction thereof shall be punished by imprisonment in the

state prison or by imprisonment in the county jail for not more than one year

(b) Every person who has in his or her possession any drugs secured by a forged

prescription shall be punished by imprisonment in the state prison or by imprisonment in the

county jail for not more than one year

11 Health and Safety Code section 11200 states in pertinent part

(b) No prescription for a Schedule III or IV substance may be refilled more than five times

and in an amount for all refills of that prescription taken together exceeding a 120-day supply

12 Health and SafetymiddotCode section 11153 subdivision (a) states

A prescription for a controlled substance shall only be issued for a legitimate medical

purpose by an individual practitioner actilg in the usual course of his or her professional p~actice

The responsibility for the proper prescribing and dispensing of controlled substances is upon the

prescribing practitioner but a corresponding responsibility rests with the pharmacist who fills the

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pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

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(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

8 Accusation

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21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

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Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

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a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

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Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

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supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

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r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

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1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

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e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

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e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

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s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

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Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

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middot 7

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middot26

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l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

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middot 23

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I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

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2

3

4

14

15

16

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6

7

8

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13

middot

middot

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17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

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10

15

20

25

II

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3

4

6

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8

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11

middot12

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16 middot

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middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

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6

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II

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23 middot

24

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b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

1

2

3

4

5

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7

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- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

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1 0

11

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e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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10

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25

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s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

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middot17

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25-middot

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middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

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y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

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f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

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~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

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I I

pr_escription Except as authorized by this division the following are not legal prescriptions (1)

an order purporting to be a prescription which is issued not in the usual course of professional

treatment or in legitimate and authorized research or (2) an order for an addict or habitual user of

controlled substances which is issued not in the course of professional treatment or middotas part of an

authorized narcotic treatment program for the purpose of providing the user with controlled

substances sufficient to keep him or her comfortable by maintaining customary use

13 California Ccide ofRegulations title 16 section 1717 subdivision (e) states

A pharmacist may transfer a prescription for Schedule III IV or V controlled substances to

another pharmacy for refill purposes in accordance with Title 21 Code ofFederal Regulations

section 130625

Prescriptions for other d~ngerous drugs which are not controlled substances may also be

transferred by direct communication between pharmacists or by the receiving pharmacists access

to prescriptions or electronic files that have been created or verified by a pharmacist at the

transferring pharmacy The receiving pharmacist shall create a written prescription identifying it

as a transferred prescription and record the date of tran~fer and the original prescription number middot

When a prescription transfer is accomplished via direct access by the receiving pharmacist the

receiving pharmacist shall notify the transferring pharmacy ofthe transfer A pharmacist at the

transferringmiddotpharmacy shall then assure that there is a record of the prescription as having been

transferred and the date oftransfer Each pharmlt~cy shall maintain inventory accountability and

pharmacist acco~ntability and dispense in accordance with the provisions of section 1716 of this

Division Information maintained by each pharmacy shall at least include

(1) Identification ofpharmacist(s) transferring information

(2) Name and identification code or address ofthe pharmacy from which the prescription

was received or to which the prescription was transferred as appropriate

(3) Original date a11d last gisp~nsing date

(4) Number of refills and date originally authorized

(5) Number of refills remaining but not dispensed

6

Accusation

(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

7

Accusation I

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

8 Accusation

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middot

21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

9

Accusation

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

10

Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

11

2

3

4

5

6

7

8

9

1o 11

12

13

middot14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

I

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

i 13I

I 14I I ll

16

17

18

19

21

22

23

24

26

27

28

a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

12

Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

2

3

4

5

6

7

8

9

1o 11

12

13

14 middot

15

16

17

18 middot

19

20

21

22

23

24

25

26

27

28

supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

l

2

3

4

5

6

7

8

9

1o 11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

f4

16

17

18

19

21

22

middot 23

24

26

27

28

e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

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23

24

25

26

27

28

middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

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

I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25 I

26

27

28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

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23

24

25

26

27

28

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

2

3

4

5

6

7

8

9

10

11

12

13

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15

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17

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19

20

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28

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

10

15

20

25

2

3

4

6

7

8

9

11

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14

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19

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23

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26

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28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

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12

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17

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19

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28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

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~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

(6) Number of refills transferred

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14 California Code ofRegulations title 16 section 1718 states

Current Inventory as used in Sections 4081 and 43 32 of the Business and Professions

Code shall be considered to include complete accountability for all dangerous drugs handled by

every licensee enumerated in Sections 4081 and 4332

The controlled substances inventories required by Title 21 CFR Section 1304 shall be

available for inspection upon request for at least 3 years after the date of the inventory

15 California Code ofRegulations title 16 section 1761 subdivision (a) states

No pharmacist shall compound or dispense any prescription which contains any significant

error omission irregularity uncertainty ambiguity or alteration Upon receipt of any such

prescription the pharmacist shall contact the prescriber to obtain the information needed to

validate the prescription middot

16 Section 4105 of the Code states

(a) All records or other documentation ofthe acquisition and disposition of dangerous

drugs and dangerous devices by any entity licensed by the board shall be retained on the licensed

premises in a readily retrievable form

(b) The licensee may remove the original records or documentation from the licensed

premises on a temporary basis for license-related purposes However a duplicate set of those

records or other documentation shall be retained on the licensed premises

(c) The records required by this section shall be retained on the licensed premises for a

period ofthree years from the date of making

(d) Any records that are maintained electronically middotshall be maintained so that the

pharmacist-in-charge the pharmacist on duty if the pharmacist-in-charge is not on duty or in the

case of a veterinary food-apimal drug retail~r or wholesaler the designated representative on

duty shaH at all times during which the licensed premises are open for business be able to

produce a hard copy and electronic copy of all records of acquisition or disposition or other drug

or dispensing-related records maintained electronically

7

Accusation I

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

8 Accusation

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middot

21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

9

Accusation

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

10

Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

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Accusation

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a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

12

Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

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supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

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r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

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e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

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e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

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Accusation

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middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

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bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

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middot 7

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middot26

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l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

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middot 23

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I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

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4

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6

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middot

middot

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18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

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10

15

20

25

II

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11

middot12

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middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

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II

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24

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b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

1

2

3

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- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

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3

4

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1 0

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e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

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8

9I j

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middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

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y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

2

3

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

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16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

2

3

4

5

6

7

8

9

10

11

12

13

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15

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17

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20

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

10

15

20

25

2

3

4

6

7

8

9

11

12

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14

16

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18

19

21

22

23

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26

27

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

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25

bull

2

3

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

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middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

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23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

5

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25

1

2

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1~

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11 (e)(l) Notwithstanding subdivisions (a) (b) and (c) the board may upon written request

grant to a licensee a waiver of the requirements that the records described in subdivisions (a) (b)

and (c) be kept on the licensed premises

(2) A waiver granted pursuant to this subdivision shall not affect the boards authority

under this section or any other provision of this chapter

17 Section 118 subdivision (b) ofthe Code provides that the

suspensionexpiratiol)surrendercancellation of a license shall not deprive the

BoardRegistrarDirector ofjurisdiction to proceed with a disciplinary action during the period

within which the license may be renewed restored reissued or reinstated

18 middot Section 1253 of the Code provides in pertinent part that the Board may request themiddot

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement ofthe case with failure ofthe licentiate to comply subjecting the license to notbeing

renewed or reinstated If a case settles recovery of investigation and enforcement costs may be

included in a stipulated settlement

CONTROLLED SUBSTANCES

19 Tylenol with Codeine a trade name for a combination of Acetaminophen and

Codeine is a dangerous drug as defined in section 4022 and a Schedule III controlled substance

and narcotic as defined by section 11056 subdivision (e) (2) of the Health and Safety Code and a

Schedule mmiddotcontrolled substance as defined by section 130813 (e) (2) ofTitle 21 ofthe Code of

Federal Regulations Codeine can produce drug dependence of the morphine type and therefore

has the potential for being abused Tylenol No 3 contains 30 mg of codeine phosphate the

maximum 24 hour dosage of codeine phosphate should not exceed 360 mg

20 Norco 10325 is brand name for Hydrocodone with Acetaminophen It is a

Schedule III controlled substance as (jesignated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dangerous drug pursuant to Business and Professions

Code section 4022

8 Accusation

5

10

15

20

25

2

3

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middot

21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

9

Accusation

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25

jmiddot

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middot

categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

10

Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

11

2

3

4

5

6

7

8

9

1o 11

12

13

middot14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

I

Accusation

5

10

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2

3

4

6

7

8

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i 13I

I 14I I ll

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a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

12

Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

2

3

4

5

6

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8

9

1o 11

12

13

14 middot

15

16

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18 middot

19

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28

supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

l

2

3

4

5

6

7

8

9

1o 11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

f4

16

17

18

19

21

22

middot 23

24

26

27

28

e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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3

4

5

6

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10

11

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

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I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

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25 I

26

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28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

2

3

4

5

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

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middot 23

24

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28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

2

3

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

10

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25

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-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

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bull

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

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9

middot1 0

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28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

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16

17

18

19

21

22

23 middot

24

26

27

28

middot

21 VicodinNicodin-ES is brand name for Hydrocodone with Acetaminophen It is a

schedule III controll~d substance as designated by Health and Safety Code section 11056

subdivision (e)(4) and is categorized as a dmgerolls drug pursuant to Business and ProfessiQns

Code section 4022

22 Phen~rgan with CoqiJe is a trade name for promethazine HCIlt is a Schedule V

controlled substance as designated by Health and Safety Code section 11 058(c)(l) and is

categoriz~q as a dangerous drug pursuant to Businyss and Professions Code section 4022 It is

primarily usecl for cough

23 Valium is brand name for Diazepam It is a Schedule IV controlled substance as

designated by Healrh and Safety Code section 11057 subdivision (0)(9) and is categorized as a

dangerous drug pursuant to Business and Prcifyssiol)s Code section 4022

24 Xanax is branq ntme for Alprazolam It is a Sphedule IV con~rollect substance as

designated by Healtli ltlnq Safety Code section 11057 subdivision ( d)(l) and is categorized as a

dlngerous drug pursuant t~ Bu~iness and Professions Code section 4022shy

25 Soma is a brand riame for Carisprodol It is categorized as a dangerous drug

pursuant to B11siness and Professions Code section 4022 Its primary indication for use is as a

muscle rela~artt

26 BaiGiPii is aQr~nd rifjme for Triazolam It is a Schedule IV coritfolleQ sqbst~nQe as

designat~o by B~a~li l-nd Safety Cocle section 11057 suboiv~siqn (d)(30) apd is Cl~egorized as a

dangerous drug pllrsuant to Business and Professions Code section 4022 Its primary indication

for use is for an~iety

27 Amlgti~n is a brand name for Zolpiqem ltis a Schedule IV controlled substance-as

desigiiated by Health arid Safity Code section 11057 s11bdivision (d)(32) and middotis categorized as a middot

dangerous drug putSUjJ1t to Business aml Professions Code section 4022 Its primary indication

for use is for insomnia

28 Suboxone is a brand nanie for Buprenorphine Itmiddotis a Schedule III controlled

substance as designated by Title 21 Code qfFederal Regulations section 130813(e)(2)(i) and is

9

Accusation

5

10

15

20

25

jmiddot

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23 middot

24

26

27

28

middot

categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

10

Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

11

2

3

4

5

6

7

8

9

1o 11

12

13

middot14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

I

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

i 13I

I 14I I ll

16

17

18

19

21

22

23

24

26

27

28

a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

12

Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

2

3

4

5

6

7

8

9

1o 11

12

13

14 middot

15

16

17

18 middot

19

20

21

22

23

24

25

26

27

28

supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

l

2

3

4

5

6

7

8

9

1o 11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

f4

16

17

18

19

21

22

middot 23

24

26

27

28

e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

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16

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middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

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23 middot

24

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bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

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16

17

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21

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middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

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16 middot

17

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28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

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6

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1o

II

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19

20

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23 middot

24

25

26

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28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

1

2

3

4

5

6

7

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28

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

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19

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21

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24

25

26

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28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

5

10

15

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25

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6

7

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21

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23

24

26

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28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

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middot17

18

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25-middot

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middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

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3

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

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I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

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2

3

4

5

6

7 middot

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

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ZO

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middot23

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f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

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12

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middot 23

24

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

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3

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

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middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

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jmiddot

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categorized as a dangerous drug pursuant to Business and Professions Code section 4022 Its

primary indication for use is opioid dependence

29 Ativan is brand name for Lorazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section I ~057 subdivision (d)(16) anlt iscate~orized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primary indication

for use is anxiety

30 KJonopin is brand name for Clonazepam It is a Schedule IV controlled substance as

designated by Health and Safety Code section n 057 subdivision (d)(7) and is categorized as a

dangerous drug pursuant to Business and Professions Code section 4022 Its primarymiddotindication

for use is anxiety and anticonvulsant

FffiST CAUSE FOR DISCIPLINE

(Filling of Erroneous or Uncertain Prescriptions and

Failure to Assume Co-Responsibility in Legitimacy of a Prescription)

(Respondents Rite Aid Pharmacy and Chung)

31 Respondent Rite Aid Pharmacy and Respondent Chung Pharmacist-in-Charge of

Respondent Rite Aid are subject to under sections 4300 and 4301 subdivision (d) and (o) ofthe

Business and Professions Code for unprofessional conduct for violating Health and Safety Code

section 11153 subdivision (a) and California Code of Regulations title 16 section 1761

subdivision (a) in that Respondents filled and dispensed prescriptions wh~ch were uncertain and

ambiguous t faHed to question whether these prescriptions served legitimate purposes and

ftirther failed to use its professional judgment to refuse to fill or refill prescriptions presented by

patients who presented as habitual doctor shoppers with erroneousuncertain prescriptions for the

following

Prescriptions presented to Rite Aid Pharmacy 5429 by customer JA

32 BetWeen June 3 2010 and May 16 2011consumer JA went to 4 different doctors to

obtain prescriptions He presented the prescriptions to Rite Aid Pharmacy 5429 which were

filled for Apap and hydrocodoneapap as follows

10

Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

11

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Accusation

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a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

12

Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

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supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

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r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

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e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

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I I I

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e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

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middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

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Ill

Ill2

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bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

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18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

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25

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3

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II

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middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

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19

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21

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24

25

26

27

28

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

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17

18

19

21

22

23

24

26

27

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

3

4

5

6

7

8

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I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25 I

26

27

28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

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

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

25

26

27

28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

a On 632010 consumer JA had Rx 54668 filled for 45 Apap 3 22 day supply by

Dr Amos

b On 6192010 consumer J A had Rx 5493 66 filled for 45 A pap 3 22 days

supply 6 days early

c On 1312011 consumer JA had Rx 594508 filled for 150 hydrocodoneapap

I 0325 25 days supply

d On 2192011 ~onsumer JA had Rx 598515 fi1led for 150 hydrocodone~pap

10325 25 day supply 6 days early

e On 3102011 consumer JA had Rx 603673 filled for 90 hydrocodone apap

10325 15 day supply 6 days early

f On 4272011 consumer JA had Rx 613670 filled for 150 hydrocodoneapap

l0325 25 day supply Dr Lahka

g On 5162011 consumer JA had Rx 611731 re~filled for 90 hydrocodoneapap

10325 15 day supply 6 days early Rx 611731 was originally filled on 41152011

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB

33 Between November 112011 and December 122011 consumer RB presented

prescriptions to Rite Aid Pharmacy 5429 which were filled for hydrocodoneapap as follows

a On 11112011 consumer RB had Rx 659685 filled for 90 hydrocodone apap

10325 22 days supply by Dr Lakha

b On 11282011 consumer RB had Rx 64095 filled for 90 hydrocodoneapap

10325 22 days supply 5 days early

c On 1222011 consumer RB had Rx 666460 filled for 90 hydrocodoneapap

10325 22 day supply 18 days early middot

d On 12122011 consumer RB had Rx 669354 filled for 90 hydrocodoneapap

10325 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 bv customer TB

34 Between August 25 2009 and October 28 2010 consumer TB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

11

2

3

4

5

6

7

8

9

1o 11

12

13

middot14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

I

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

i 13I

I 14I I ll

16

17

18

19

21

22

23

24

26

27

28

a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

12

Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

2

3

4

5

6

7

8

9

1o 11

12

13

14 middot

15

16

17

18 middot

19

20

21

22

23

24

25

26

27

28

supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

l

2

3

4

5

6

7

8

9

1o 11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

f4

16

17

18

19

21

22

middot 23

24

26

27

28

e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

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16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

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17

18

19

20

21

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25

26

27

28

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

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17

18

19

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

3

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5

6

7

8

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19

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28

I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25 I

26

27

28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

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

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

25

26

27

28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

i 13I

I 14I I ll

16

17

18

19

21

22

23

24

26

27

28

a On 8252009 consumer TB had Rx 479013 filled for 60 hydrocodoneapap

751750 12 day supply by Dr Pacheco

b On 912009 consumer TB had Rx 479013 refilled for 60 hydrocodoneapap

75750 1~ day supply 5 days early

c On I 11302009 consumer TB had Rx 511071 filled for 60 hydrocodoneapap

75750 30 day supply

d On 122112009 consumer TB had Rx 515055 filled for 60 hydrocodoneapap

75750 30 day supply 8 days early

e On 6242010 consumer TB had Rx 547591 filled for 60 hydrocodoneapap 75

30 days supply byDr Castro

f On 782010 consumer TB had Rx 547591 refilled for 60 hydrocodoneapap 75

16 days early

g On 924201 0 consumer TB had Rx 567365 filled for 60 hydrocodoneapap 30

day supply by Dr Pacheco On 10162010 Rx 567365 filled for 60 hydrocodoneapap 75 30

day supply 8 days early

h On 10282010 consumer TB had Rx 576154 filled for 60 hydrocodoneapap 75

30 days supply 18 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RB (2)

35 Between February 22 2011 and January 23 2012 consumer RB (2) presented

prescriptions to Rite Aid Pharmacy 5429 for diazepam and hydrocodoneapap which were fi11ed

as follows

a On 2222011 consumer RB (2) had Rx 587403 filled for 30 diazepam 10 mg 30

day supply by Dr middotoganyan

b On 332011 consumer RB (2) had Rx 602173 filled for 30 diazepam 10 mg 30

day supply 21 daysearly

c On 3212011 consumer RB (2) had Rx 606241 filled for 30 diazepam 10 mg 30

day supply 11 days early

12

Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

2

3

4

5

6

7

8

9

1o 11

12

13

14 middot

15

16

17

18 middot

19

20

21

22

23

24

25

26

27

28

supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

l

2

3

4

5

6

7

8

9

1o 11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

f4

16

17

18

19

21

22

middot 23

24

26

27

28

e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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

middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

3

4

5

6

7

8

9

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11

12

13

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15

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17

18

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21

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24

25

26

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28

I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

9

10

11

12

13

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21

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23

24

25 I

26

27

28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

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20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

2

3

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5

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

10

15

20

25

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28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

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25

bull

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

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14

15

16

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24

25

26

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28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

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13

14

15

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23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

d On 4(62011 consumer RB (2) had Rx 606241 filled for 30 diazepam long 30 day

2

3

4

5

6

7

8

9

1o 11

12

13

14 middot

15

16

17

18 middot

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25

26

27

28

supply 14 days early

e On 4232011 consumer RB (2) had Rx 60273 filled for 30 diazepam 10 mg 30

days supply 13 days early

f On 5182011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30

day supply

g On 652011 consumer RB (2) had Rx 618613 filled for 30 diazepam 10 mg 30 day

supply 12 days early

h middot On 6282011 consumer RB (2) hadmiddotRx 618613 filled for 30 diazepam 10 mg 30

days supply 7 days early

i On 7132011 consumerRB (2) hadRx 630459 filled for 30 diazepam 10 mg 30

day supply 14 days early

j On 10122011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 nig 30

days supply

k On 11112011 consumer RB (2) had Rx 652621 filled for 30 diazepam 10 mg 30

day supply 10 days early

l On 11212011 consumer RB (2) had Rx 6 52621 filled for 30 diazepam 1 0 mg 10

days early

m On 1282011 consumer RB (2) had Rx 668302 filled for 30 diazepam 10 mg 30

day supply

n On 12282011 consumerRB (2) had Rx 668302 filled for 30 diazepamIO mg 30

day supply 10 days early

o On 142012 consumer RB (2) had Rx 673968 filled for 30 diazepam 10 mg 13

days early

p On 11212011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 30 day supply

q On 1282011 consumer RB (2) had Rx 663543 filled for 90 hydrocodoneapap

75750 13 days early and filled again on 152012 30 day supply

13

Accusation

l

2

3

4

5

6

7

8

9

1o 11

12

13

14

15

16

17

18

19

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21

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24

25

26

27

28

r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

f4

16

17

18

19

21

22

middot 23

24

26

27

28

e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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

middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

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I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

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25 I

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28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

2

3

4

5

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28

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

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27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

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9

10

11

12

13

14

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middot 23

24

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28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

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25

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-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

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25

bull

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

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middot1 0

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middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

l

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r On 11232012 consumer RB (2)had Rx 679710 filled for 90 hydrocodoneapap

75 12 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer PB middot middotmiddot middot middot

36 Between October 21 20llmiddotand October 222011 consumer PB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrooodoneapap which were filled as follows

a On 10212011 consumer PB had Rx 654986 filled for 90 hydrocodoneapap

75750 30 days supply by Dr Casillas

b On 10222011 consumer P B had Rx 655286 filled for 60 hydroco~oneapap

75 20 day supply by Dr Uche 28 days early

Prescriptions resented to Rite Aid Pharmacy 5429 by custmer LB

37 Between March 30 2011 and April14 2911 consumer LB presented

prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as follows

a On 3302011 consu~er LB had Rx 608196 filled for 45 hydrocodopeapap

1032522 day supply by Dr Amos

b On 414Z011 consumer LB had Rx 611482 filled for 45 hydrocodoneapap

10325 by Dr Hineman 7 days early

Prescrigtions presented to Rite Aid Pharmacv5429 by customer RB(3)

38 Between March 30 2011 arid Aprill4 2011 cm1sumer RB (3) presented

prescriptions to Rite Aid Ph8rrhacy 5429 for hydrocodoneapap which were fiJied as follows

a On 1262011 consumer RB(3) had -Rx -594-505 filled for 90 hydrocodoneapap

10325 22 clay supply by Dr R Lakha

b On 2102011 consumer RB(3) had Rx 596506 fil)ed for 90 hydrocodoneapap

-

1032522 day supply 7 days early

c On 342011 consumer RB(3) had Rx 602521 filled for 90 hydrocodoneaplp 22

day supply 10 days early

d On 632011 consumer RB(3) had Rx 621917 filled for 90 hydrocodoneapap 22

day supply 7 days early

14

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

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12

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f4

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middot 23

24

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28

e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

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28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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

middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

3

4

5

6

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8

9

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11

12

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15

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21

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24

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28

I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

9

10

11

12

13

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21

22

23

24

25 I

26

27

28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

2

3

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

10

15

20

25

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-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

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25

bull

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

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26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

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14

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23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

5

10

15

20

25

2

3

4

6

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11

12

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f4

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middot 23

24

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28

e On 8192011 consumer RB(3) had Rx 639079 filled for 90 hydrocodone apap

I 0325 22 days supply 6 days early

f On 932011 consumer RB(3) had Rx 641513 filled for 90 hydrocodoneapap

10325 22 day supply 7 days eaiy

g On 9192011 consumer RB(3) had Rx 646525 filled for 90 hydrocodoneapap

1032522 days supply 6 days early

h On 1042001 consumer RB(3) had Rx 648240 filled for 90 hydrocodorieapap

10325 22 day supply 7 days early

i On 10192011 consumer RB(3) had Rx 653716 filled for 90 hydrocodoneapap

22 day supply 7 days early

j On 1132011 consumer RB(3) had Rx 658465 filled for 90

hydrocodoneapap1 0325 22 day supply 7 days early

k On11172011 consumer RB(3) had hadRx 661225 filled for 90 hydrocodone

apap l0325 22 day supply 8 days early

I On 11232011 consumer RB(3) had Rx 664096 filled for 90 hydrocodoneapap

1032522 day supply 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SB

39 Between April14 2009 and October 21 2011 consumer SB who went to 16

doctors and 5 pharmacies within this time period presented prescriptions to Rite Aid Pharmacy

5429 for hydrocodoneapap which were fi11ed as follows

a On 10i212011 consumer SB had Rx 655458 filled for 30 alprazolam 1 mg 15

day supply by Dr S Ho

b On 1 0262011 consumer SB had Rx 655458 refi1led for 30 alprazolam 1 mg 10

days early middot

c On 4162009 consumer SI3 had Rx 466989 refilled for 60 alprazolam 2 mg 30 day

supply by Dr C Charistian 16 days early middot

d On 562009 consumer SB had Rx 473496 filled for 60 alprazolam 2 mg 30 day

supply by Dr Christian 9 days early

15

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

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16

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19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

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24

26

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28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

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25

26

27

28

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

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21

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24

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

3

4

5

6

7

8

9

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16

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18

19

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28

I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25 I

26

27

28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

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

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

25

26

27

28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

~ 27

28

I I I

i

I

i

i ~~

i

e On 652009 consumer SB had Rx 478051 refilled for 60 alprazoiam 2 mg30

days supply by Dr F Rundall 26 days early

f middot On 6122009 consumer SB had Rx 478051 refilled for 60 alprazolam 2 mg 30

days supply 23 days early

g On 6192009 consumer SB Rx 481847 filled for 60 alprazolam 2 mg 30 days

supply by Dr Rundall 23 days early

h On 8ll2Q09 consumer SB had Rx 490374 refilled for 30 alprazolam 2 mg 15

day supply by Dr Christian 10 days early

L On 9152011 consumer SB had Rx 496572 refilled for 30 alprazolam 2 mg 15

day supply by Dr Charistian 10 days early and again on 9252009

j On 1012009 ccmsumer SB had Rx 49q572 refilled for 30 alprazolam 2 mg 15

day supply 8 days early

k On 10102009 consumer SB had Rx 501604 filled for 30 alprazolam 2 mg 15

day supply by Dr Rundall 6 days early bull

I On 10162009 consumer SB had Rx 501604 refilled for 30 alprazolam 2 mg 15

day supply 9 days early

m On 1162009 consumer SB had Rx 507087 filled for 60 alprazolam 2mg 30 day

supply by Dr Christian

n On 11172009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 15

day supply (DS) by Dr D Amos 19 days early

o On 11212009 consumer SB had Rx 508939 filled for 30 alprazolam 2 mg 10 days

early

p On 1212009 consumer SB middothad Rx 511332middotfilled for 30 alprazolam 2 mgmiddot15 DS

by Dr D Amos

q On 1252009 consumer SB had Rx 511332 filled for 30 alprazolam 2 mg 9 days

early

r On 12172009 consumer SB had Rx 514401 filled for 30 alprazolam 2mg 15 DS

by Dr C Christian

16

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

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middot 23

24

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I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

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17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

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10

15

20

25

II

2

3

4

6

7

8

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11

middot12

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16 middot

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28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

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5

6

7

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9

1o

II

12

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19

20

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23 middot

24

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b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

1

2

3

4

5

6

7

8

9

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28

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

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18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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10

15

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25

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s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

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middot17

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middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

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y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

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3

4

5

6

7 middot

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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3

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

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

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

25

26

27

28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

5

10

15

20

25

r q I

2

i 3

I

I 4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

middot

s On 12212009 consumer SB had Rx 51440 1 filled for 30 alprazolam 2 mg 11

days early

t On 2162010 consumer SB had Rx 525423 filled for 30 alprazolam2 mg 15 DS

qy Dr D Amos

u On 2182010 consumer SB had Rx 525423 filledfor 30 alprazolam 2 mg 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RC

40 Between March 5 2010 and December 3 2010 consumer RC who went to 6

doctors for prescriptions presented prescriptions to Rite Aid Pharmacy 5429 for triazolam

which were filled as follows

a On 352010 consumer RC had Rx 524863 filled for 30 triazolam 025 mg 30 DS

by Dr K Wong

b On 3272010 consume~ RC had Rx 524863 filled for 30 triazolam 025 30 DS 8

days early

c On 4192010 consumer RC had Rx 524863 filled for 30 Triazolam 025 30 DS

8 days early

d On 51112010 consumer RC had Rx 524863 filled for 30 triazolam 025 30 DS

e On 622010 consumer RC had Rx 544315 filled for 30 triazolam 025 30 DS by

Dr V Bustamente 8 days early

f On 6302010 and 7262010 consumerRC had Rx 544315 refi11ed for 30

triazolam 025 30 DS

g On 8172010 consumer RC had Rx 544315 refilled for 30 triazolam 025 30 OS

8 days early

h On 10222010 consumer RC had Rx 574199 filled for 30 triazolam 025 30 DS

L On 1182010 consumer RC had Rx 574199 refilled for 30 triazolam 025 30 DS

15 days early

j On 11272010 consumer RC had Rx 576371 filled for 30 triazolam 025 30 DS

by Dr V Bustamente

17 Accusation I

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

28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

27

28

bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

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23 middot

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b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

1

2

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28

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

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6

7

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9

1 0

11

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e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

5

10

15

20

25

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3

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6

7

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s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

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16

middot17

18

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24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

2

3

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5

6

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

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I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

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10

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ZO

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middot23

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f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

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middot 23

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

2

3

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

10

15

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25

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27

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

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25

bull

2

3

4

6

7

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9

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18

19

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

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21

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27

28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

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16

17

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19

21

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28

k On 1212010 consumer RC had Rx 582717 filled for 30 triazolam 025 30 DS by

Dr A Chai 26 days early

I On 1232010 consumer RC~ad Rx 583219 filled for 31 triazolam 025 31 DS

by_Dr A Chai 29 days early

Prescriptions presen~ed to Rite Aid Pharmacy 5429 by customer HC

41 Between August 16 2010 and January 7 2012 consumer HC presented

prescription~ to Rite Aid Pharmacy 5429 During this time period he went to 13 doctors and 9

pharmapies for controlled substances

Prescriptions presente~ to Rite Aid Pharltlacy 5429 by customer JD

42 Between March 2 2009 and April 15 2011 consumer JD who went to 12

doctors for prescriptions and 4 pharmacies presented prescriptions to Rite Aid Pharmacy 5429

for hydrocodoneapap which were filled as follows

a middot On 372009 consumer JD had Rx 462123 filled for 60 hydrocodoneapap 5500

30 DS by J Mays 10 days early

b On 5272009 consumer JD had Rx 477314 filled for 30 hydrocodoneapap 5500

15 DS by Dr Mays

c On 612009 consumer JD had Rx 477314 refilled for 30 hydrocodoneapap

5500 15 DS 10 days early

d On 682009 consumer JD had Rx middot479380 filled for 30 hydrocodoneapap 5500

10 DS by Dr Adetola 8 days early

e On 12152009 consumer JD had Rx 514165 filled for 35 hydrocodoneapap

5500 35 DS by J Mays

t On 12302009 consumer JD had Rx 5165 89 filled for 30 middothydrocodoneapap 5500

5 DS by Dr N Dzebolic 20 days early

g On 4122011 consumer JD had Rx 611185 filled for 15 hydrocodoneapap 5500

15 DS by J Mays

h On 41152011 consumer JD had Rx 611185 refilled for 15 hydrocodoneapap

550012 days early

18

Accusation

5

10

15

20

25

Ill

Ill2

3

4

6

7

8

9

11

12

13

14

middot

16

17

18

19

21

22

23 middot

24

26

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bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

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middot26

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l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

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middot 23

24

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28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

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17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

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middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

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28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

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- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

5

10

15

20

25

2

3

4

6

7

8

9

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17

18

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21

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23

24

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28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

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13

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15

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middot17

18

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25-middot

26

27

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middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

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I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

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2

3

4

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6

7 middot

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

2

3

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

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12

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14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

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middot 23

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28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

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25

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-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

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bull

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

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9

middot1 0

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middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

5

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Ill

Ill2

3

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middot

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bullbullj

Prescriptions presented to Rite Aid Pliarmacy 5429 by customer JF -~- ~ ~ middot middot

43 Between DeceJber 20 2010 and Novertiber 15 2011 consumer JF presented

prescriptions to Rite Aid Pharmacy 5429 for ~yqrocodoneapap which were filled as fqllows

a On 12402010 consmiddotumer JF had Rx 586842 filled for 3 0 Alpraiolam 2 mg 13

days early

b On 112412011 consumer JF had Rx 593881 fill~d for 60 hydrocodoneapap

101325 10 DS by Dr Lakha

c On 1252011 consumer JF had Rx 593887 filled for 60 hydrocodo11eapap

10325 9 days early

d On 3113~011 consumer JF hac Rx 603674 filled for 120 hydrocodorieapap

101325 20 DS by Dr Lakha

e On 3172011 consumer JF had Rx 605518 filled fot 120 hyqrocodone1 0325 20

DS 16 days early

f On 33112011 consumer JF h~d Rx 608397 filled for 120 hydrocodoneapap

10132522 dlttys early

g On 71812011 consumer JF had Rx 629245 fiHed for 120 hyjlrocoqoneapap

10325 20 DS

h On 71142011 consumer JF had Rx 630608 fill~d for 120 hydrocooon~ap11p

1032520DS

i middot On 7124IZ011 consuJTier JF ll~d Rx 632619 nll~d for 120 hyqrocodo~eapap

10325 10 days early

j On 912712011 consumer JF h(ld Rx 646910 filled for 120 hydrocodonelapap

10132520 DS

k On 91292011 consumer JF had Rx 649041 filled for 120 hydrocodoneapap

10325 18 days early

19

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

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24

middot26

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28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

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15

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25

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II

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middot 23

24

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28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

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23

24

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26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

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21

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23

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28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

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23 middot

24

25

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28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

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28

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

5

10

15

20

25

2

3

4

6

7

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17

18

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21

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23

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28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

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14

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16

middot17

18

19

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25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

2

3

4

5

6

7

8

9

10

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12

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

3

4

5

6

7

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I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

9

10

11

12

13

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25 I

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28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

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

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

25

26

27

28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

5

10

15

20

25

2

3

4

6

middot 7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

middot26

27

28

l On 1132011 consumer JF had Rx 657908 filled for 120 hydrocodoneapap

10325 20 DS

middot m On 11152011 consumer JF had Rx 660117 filled for 120 hydrocodoneapap

10325 20 DS 8 days early

Prescriptions presentedto Rite Aid Pharmacy 5429 by customer SF

44 Consun4er SF who went to 19 doctors for prescriptions middotand 4 pharmacies

presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which were filled as

follows

a On 11152010 consumer SF had Rx 519943 filled for 120 hydrocodoneapap

10325 30 DS by Dr D Ricklis

b On 11282010 consumer SF had Rx 521962 filled for 120 hydrocodoneapap

10325 15 DS by Dr B Chaudry 17 days early

c On 6162010 consumer SF had Rx 549416 filled for 120 hydrocodoneapap

1032530 DS by Dr B Collins

d On 752010 consumer SF had Rx 552283 filled for 60 hydrocodoneapap 10325

15 DS by Dr B Chaudry 10 days early On 752010

e On 7142010 consumer SF had middotRx 555066 filled for 120 hydrocodoneapap

10325 15 DS by Dr W Mao 16 days early

f On 12102010 consumer SF hadRx 585027 filled for 120 hydrocodoneapap

10325 20 DS by Dr L Hashemi

g On 12232010 consumer SF had Rx 585027 refilled for 120 hydrocodoneapap

10325 7 days early

h On 232011 consumer SF had Rx 596345 filled for 60 hydrocodoneapap 10325

20 DS by Dr S Desai

i On 21020 11 consumer ~F had Rx 597839 filled for 60 hydrocodoneapap

10325 20 DS 13

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer SK

20

Accusation I

5

10

15

20

25

2

3

4

6

7

8

9

II

12

13

14

16

17

18

19

21

22

middot 23

24

26

27

28

I

45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

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23

24

25

26

27

28

middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

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

I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25 I

26

27

28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

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25

26

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28

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

14

16

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18

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21

22

23

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26

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28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

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28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

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45 Consumer SK presented prescriptions to Rite Aid Pharmacy 5429 for

alprazolam which were filled as follows

a On middot472009 consumer SK had Rx 465434 filled for 60 alprazolam 1 mg 30

DS

On 4162009 consumer SK haci Rx 465434 filled for 60 alprazolam 1 mg 30

DS 21 days early

c On 472009 consumer SK had Rx 465431 filled for 60 hydrocodoneapap

550030 DS

d On 4162009 consumer SK had Rx 465431 filled for 60 bydrocoqoneapap 5500

21 days early

e On 4232009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 30

DS

f On 4302009 consumer SK had Rx 471224 filled for 30 zolpidem 10 mg 23

days early

g On 8172009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 30

DS

h On 8212009 consumer SK had Rx 491855 filled for 30 zolpidem 10 mg 26

days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer LL

46 Consumer LL who went to 7 coctors for prescriptions and 7 pharmacies during

this time period presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap middot

which were filled as foliows

a middot On 1222011 consumer LL had Rxmiddot 666330 filled for 50 hydrocodoneapap

10325 12 DS by Dr E Levente

b On 12~201I consumer LL had Rx 666330 filled for 50 hydrocodoneapap

10325 12 DS 9 days early

c On 1282011 consumer LL had Rx 666330 filled for 47 hydrocodoneapap 10325

11 DS 18 days early

21

Accusation

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18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

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middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

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b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

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e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

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middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

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y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

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

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

25

26

27

28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

1

2

3

4

14

15

16

5

6

7

8

9

10

11

12

13

middot

middot

19

20

21

22

23

24

25

26

27

28

17

18 middot

d On 121112011 consumer LL had Rx 666330 filled for 3 Hydrocodoneapap 1

day supply 26 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WL bull middot shy middot ___ -middotmiddot

47

2012 and a total of 45 doctors for prescriptions and 7 pharmacies during this time presented

prescriptions to Rite Aid Pharmacy 54~9

P~escriptionspresented to Rite Aid Ph~rmac)r 5429 by customer CL

48 Consumer CL who went to bejW~enappr~ximately 5 to 13 doctors within 5 months middot middotmiddot middotmiddotmiddotmiddot

and 9 pharmacies during this time presented prescriptions to Rite Aid Pharmacy 5429

Prescriptions presented to Rite Aid Plritnl~cymiddot~429 by customer AM middotmiddot middotmiddot middot middotmiddot

49 Consumer AM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 3152011 consumer AM had Rx 604067 filled for 90 hydrocodoneapap

10325 30 DS

b On 3212011 consumer AM had Rx 606134 for 90 hydrocodoneapap 10325

30 DS 24 days early I

c On 41142011 consumer AM had Rx 609993 filled for 90 hydrocodoneapap

10325 30 DS 9 days early

d On ~21022 consumer AM had Rx 614878 filled for 90 hydrocodoneapap

10325 30 DS 12 days early

e On 5122011 consumer AM had Rx 617318 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

f middot On 5242011 consumer AM had Rx 619Tl7 filled for 90 hydrocodoneapap

1032530 DS 18 days early

g On 692011 copsurner AM had Rx 623012 filled for 90 h~drocodoneapap

1032530 DS 16 days early

h On 6282011 consumer AM had Rx 624898 filled for 90 hydrocodoneapap

10325 30 DS 11 days early

22 Accusation

5

10

15

20

25

II

2

3

4

6

7

8

9

11

middot12

13

14

16 middot

17

18

19

21

22

23

24

26

27

28

middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

2

3

4

5

6

7

8

9

1o

II

12

13

14

15

16

17

18

19

20

21

22

23 middot

24

25

26

27

28

b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

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17

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23

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25

26

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28

middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

3

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5

6

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9

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11

12

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I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

9

10

11

12

13

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24

25 I

26

27

28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

2

3

4

5

6

7

8

9

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11

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15

16

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18

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26

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28

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

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18

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21

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middot 23

24

25

26

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28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

2

3

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

10

15

20

25

2

3

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-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

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25

bull

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

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24

25

26

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28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

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23

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

5

10

15

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25

II

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middot12

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middot middotmiddot

middot i On 7192011 consumer AM had Rx 631706 filled for 90 hydrocodoneapap

1032530 DS 8 days early

j On 7292011 consumer AM had Rx 634354 filled for 90 hydrocQdcineapap

1032530 DS 20 days early

k On 8162011 consumer AM had Rx 638293 filled for 90 hydrocodoneapap

1032530DS l3daysearly

I OJ 8312011 consumer AM had Rx 641907 filled for 90 hydrocodoneapap

1032530 DS 15 days early

m On 9102011 consumer AM had Rx 644392 filled for 90 hydrocodoneapap

10325 30 DS 20 days early

n On 9132011 consumer AM had Rx 645080 filled for 90 hydrocodoneapap

10325 30 DS 27 days early

o On 9282011 consumer AM had Rx 647790 filled for 90 hydrocodoneapap

10325 30 DS 15 days early

p On 1062011 consumer AM had Rx 650865 filled for 90 hydrocodoneapap

10325 30 DS 21 days early

q On 10282011 consumer AM had Rx 653162 filled for 90 hydrocodoneapap

10325 30 DS 8 days early

r On I 1112011 consumer AM had Rx 660732 filled for 90 hydrocodoneapap

10325 30 DS 17 days early

s On 11282011 consumer AM had Rx 664800 filled for 90 hydrocodoneapap

10325 13 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer NM

50 Consumer NM who went to between approximately 2 to 8 doctors and 6

pharmacies during thismiddot time presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 7152011 consumer NM had Rx 630998 filled for 150 hydrocodoneapap 751750 37 DS by Dr J Borovic

23

Accusation I

I I

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1o

II

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19

20

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23 middot

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25

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b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

1

2

3

4

5

6

7

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28

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

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1 0

11

12

13

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21

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e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

5

10

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25

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s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

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middot17

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middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

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3

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

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I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

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2

3

4

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6

7 middot

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

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10

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12

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ZO

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middot23

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f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

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12

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middot 23

24

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

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3

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

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Ill

Ill

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e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

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b On 7262011 consumer NM had Rx 630998 filled for 150 hydrocodoneamppap

75750 37 DS 26 days early

c On 882011 consumer NM had Rx 636130 filled for 150 hydrocodoneapap

75750 37 DS 24 days early middotmiddotmiddot

d middoton 8122011 consumer NM had Rx 637422 flll~d for 120 hydrocodoneapap

75750 30 DS by Dr A Weinberg 33 days early

middot e On 982011 consumer NM had Rx 643767 filled for 60 hydrocodoneapap

75750 15 DS by Dr Weinberg

f On 9142011 consumer NM had Rx 645560 filled for 150 hydrocodoneapap

75750 37 bs by Dr Bcirovic 8 days early

g On 10122Dll consumer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 9 d~ys eady

h On 10262011 cori~tlmer NM had Rx 652655 filled for 150 hydrocodoneapap

75750 37 DS 23 days early

i On 1162011 consumer NM had Rx 659168 filled for 60 hydrocodoneapap

75750 30 DS by Dr A V[einberg 26 days early

j On 11182011 consumer NM hampd RX 662988 fil)ed for 150 hydrocodone~pap

75750 37 DS ByDr 3orovic 18 days early

k On 1252011 consumer NM had Ex 666997 filled for 150 hydrocodoneapap

757S037DS 19 days early

1 On 121142011 consumer NM had Rx 666997 filled for 150 hyltirocodoneapap

75750 37 DS 2S days early

rh middoton 132011 consumerNM h~d Rx 675571 filled for 150 hydrocodoneapajr

75150 17 days ear)y

Prescriptions presented to Rite Aid Pharma~y 5~29 by customer BM

51 Consumer BM presented prescriptions to Rite Aid Pharmacy 5429 for

669 DS of Suboxone between 12210 and 121611 totEling 362 days

Prescriptions presente~ to Rite Aid Ph~rmacy ~5429 bv customer WM

24 Accusation

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- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

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n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

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e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

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gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

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-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

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y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

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

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

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9

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17

18

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22

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28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

25

26

27

28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

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17

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21

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28

- -~- middotmiddot-- bullbull - __ ~--

52 Consumer WM presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 962010 consumer WM had Rx 565136 filled for 60 hydrocodoneapap

757500 DS

b On 9292010 consumer WM had Rx 567049 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

c On 1212011 consumer WM had Rx593582 filled for 60 hydrocodoneapap

75750 30 DS

d On 2132011 consumer WM had Rx 593582 filled for 60 hydrocodoneapap

75750 30 DS 7 days early

e On 232009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS

f On 262009 consumer WM had Rx 448587 filled for 30 hydrocodoneapap

5500 30 DS 27 days early

g On 332009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS

h On 3262009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

550030 DS 7 days early

i On 432009 consumer WM had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 23 days early

j On 4222009 consumer W~M had Rx 461058 filled for 30 hydrocodoneapap

5500 30 DS 11 days early

k middot On 54200~ consumer WM had Rxmiddot 472874 filled for 30middothydrocodoneapap

550030 DS 18 days early

1 On 5119(2009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

550030-DS 18 days early

m On 6112009 consumer WM had Rx 472874 filled for 30 hydrocodoneapap

5500 30 DS

25

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

4

5

6

7

8

9

1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

5

10

15

20

25

2

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6

7

8

9

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12

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23

24

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27

28

s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

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I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

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18

19

ZO

21

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middot23

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f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

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middot 23

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

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middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

I I I i

n On 6222009 consumer WM had Rx 472874 filled for 30 hygrocodoneapap

5500-30 DS 19 days early

o On 762009 consumer WM had Rx 483727 filled for 30 hydrocodoneapap middot

55001 16 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer WN

53 Consumer WN who went to between approximately 3 and 8 doctors and 7

pharmacies within a year presented prescriptions to Rite Aid Pharmacy 5429 for

hydrocodoneapap which were filled as follows

a On 8112011 consumer WN had Rx 637252 filled for 90 hydrocodone 75750 by

Dr D Amos

b On 8292011 consumer WN had Rx 641282 filled for 90 hydrocodoneapap

751750 22 DS 12 days early

c On 9122011 consumer WN had Rx 644841 filled for 90 hydrocodoneapap

75750 8 days early

Prescriptions presented to Rite Aid Pharmacy 5429 by customer RP

54 Between March 16 2010 and January 262012 consumer RP went to 19 doctors

for 3 different strengths ofhydrocodoneapap according to records at Rite Aid Pharmacy

Additional reports showed she saw 23 doctors and went to 13 pharmacies during the same time

period She presented prescriptions to Rite Aid Pharmacy 5429 for hydrocodoneapap which

were filled as follows

a On 12272010 consumer RP had Rx 587948 filled for 60 hydrocodone apap

75750 30 DS by Dr Rojo

b On 12312011 consumer RP had Rx 589088 filled for 3() hydrocodone apap

75750 10 DS by Dr M Kohmima 26 days early

c On 3242011 ccmsumer RP had Rx 606889 fill~d for 50 hydrocodone apap

75750 16 DS by Dr D Amos

d On 3262011 consumer RP hadRx 606889 filled for 40 hydrocodone apap

75750 14 days early

26

Accusation

2

3

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1 0

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e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

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s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

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4

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9I j

10

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middot17

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25-middot

26

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middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

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I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

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6

7 middot

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

2

3

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

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18

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ZO

21

22

middot23

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f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

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middot 23

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

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25

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-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

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bull

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

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9

middot1 0

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middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

2

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1 0

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e On 612011 consumer RP had Rx 621550 filled for 60 hydrocodone apap

75750 30 DS by Dr L Montecito

f On 6112011 consumer RP had Rx 623563 filled for 35 hydrocodone apap middot middot

75750 35 DS lJyDr J Mays 20 days early

g On 6162011 consumer R~P had Rx 624654 filled for 100 hydrocodcine apap

75750 33 DS by Dr D Amos 30 days early

h On 772011 consumer RP had Rx 629179 filled for 30 hydroc~done apap

75750 by Dr F Chu 11 days early

i On 7252011 con9umer RP had Rx 633165 filled for 60 hydrocodone apap

7517 50 20 DS middotby Dr N Anakwenze

j On 842011 consumer RP had Rx 635513 filled for 60 hydrocodone apap

75750 15 DS by Dr F Chu 10 days early

k On 8252011 consumer RP had Rx 640667 filled for 60 hydrocodone apap

75750 20 DS by Dr N Anakwenze

I On 912011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

751750 30 DS 13 days early

m On 992011 consumer RP had Rx 642283 filled for 60 hydrocodone apap

75750 30 DS 22 days early

n On 9162011 consumer RP had Rx 646279 filled for 60 hydrocodone apap

75750 60 DS by Dr C Okoye 23 days early

o On 10292011 consuller RP had Rx 657247 filled for 60 hydrocodone apap

75750 30 DS by Dr C Okoye

p On 11142011 consumer RP hactmiddotRx 660955 filled for 50 hydrocodone apap

75750 by Dr J Soliman 14 days early

q On 1222011 consumer RP had Rx 593791 fille~ for 100 hydrocodoneapap

10325 33 DS by Dr M Kohanim

r On 2112011 consumer RP had Rx 598125 filled for 50 hydroccidoneapap

10325 16 DS 13 days early

27 Accusation

5

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s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

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28

middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

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I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

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10

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25 I

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28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

2

3

4

5

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

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middot 23

24

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28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

2

3

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

10

15

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25

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-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

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bull

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

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5

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9

middot1 0

11

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middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

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s On 2202022 consumer RP had Rx 598125 filled for 50 hydrQcodoneapap

I 0325 16 DS 7 d~ys early

t On 7142011 consumer RP had Rx 630586 filled for 50 hydrocodoneapap

10325 12 DS by Dr D Amos

u On 7152011 consumer ~P had Rx 630586 filled for 50 hydrocodoneapap

I 0325 12 DS 11 days early

v On 1052011 consumer RP had Rx 650830 filled for 60 hydrocodoneapap

10325 20 DS qy Dr 0 Wallace

w On 1092011 consumer RP had Rx 650830 filled for 30 hydrocodoneapap

10325 10 DS 16 days early

x On 10102011 consumer RP had Rx 651837 filled for 90 hydrocodcmeapap

10325 30 DS by J Rojo 9 days early

y On 112120ll consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS by Dr A Sefa

z On 111232011 consumer RP had Rx 663197 filled for 60 hydrocodoneapap

10325 15 DS 13 days early

aa On 1222011 consumer RP had Rx 663197 filled for 120 hydrocodoneapap

1032530DS

bb On 12192011 consumer RP had Rx 663197 filled for50 hydrocodoneapap

1032512 DS T3-days early

middot cc On 12242011 consumer RP had Rx 663197 filled for 70 hydrocodoneapap

10325 17 DS 7 days early

dd On 12262011 consumerRP had Rx 663197 filled for 120 hydrocodoneapap

1032530 DS 13 days early

ee On 122012 consumer RP had Rx 663197 filled_for 50 hydrocodoneapap 10(32~

12 DS 23 days early

ff On 192012 consumer RP hadmiddotRx 663197 filled for 50 hydrocodoneapap 10325

12 DS 5 days early and filled again on 1262012 for 20 hydrocodoneapap 1 0325 5 DS

28

Accusation I

I

1

2

3

4

5

6

7

8

9I j

10

11

12

13

14

15

16

middot17

18

19

20

21

22

23

24

25-middot

26

27

28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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3

4

5

6

7

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9

10

11

12

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

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I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

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25 I

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28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

2

3

4

5

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

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middot 23

24

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28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

2

3

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

10

15

20

25

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-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

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bull

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

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9

middot1 0

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middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

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23

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

I

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middot17

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28

middot

gg On 8122Q1lconsumer RP had Rx 637374 filled for 45 hydrocodorieapap

10325 15 bs by Dr D Amos

hh On 8132011 consumer RP had Rx 3 637374 filled for 45 hydrocodoneapap

I 0345 13 days early middot middot

Prescriptions preseii~~d to Rit~ AidmiddotPharmacy 5429 by-customer VR middotmiddot

55 Between June 19 i009 and December2 2011 Consumer VR went to between

14 and 17 c~ctors ancjJl pharmacies and presented prescriptions-to Rite Aid Pharmacy 5429

for alprazol~m hydrocodoneapap and hydrornorp~one which were filled as follows

a On 7122010 consumer VR hadRx 554375 filled for 60 alprazolarn2 mg 30 DS

by Dr D Ames

b On 71720iQ consumer VR had Rx 555618 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 25 d~ys early middot

c On 7312010 consumer VR hac) Rx 558330 fillecj for 60 alprazolam 2 mg 30 DS

by Dr D Amos 16 days e~rly

d On 811201Imiddotconsurher VR had Rx 560524 filled for 60 alprazola1112 mg 30 DS

19daysearly

e On 8232010 consumer VR had Rx 562722 filled for 60 alprazolam 2 mg 30 DS

by Dr J Rojo 18 days early

f On 8312010 consumer VR had Rx 564090 fild for 60 alprazolam 2 mg 30 DS

by Dr _b Amos 22middot days early

g On 9132010 consumer VR had Rx 566913 filled for 60 alprazolam 2 mg 30 DS

17 days early

h On 1042010 consumer VR haC Rx 570951 fil~d for 60 alpr~cilam 2 mg 15 DS middot

9 days early

i On 10182010 consumer VR Qad Rx 573685 fill~d for 60 aJprazol~m 2 mg 30

DS by J R~jo

j On 10282010 consumer VR had Rx 576028 filled for 60 alprazolam 2 mg by

Dr D Amos 20 days early

29

Accusation

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

2

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I

I I I

y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

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7 middot

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

2

3

4

5

6

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

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5

6

7

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14

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ZO

21

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middot23

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28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

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middot 23

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~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

10

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25

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-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

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bull

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

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9

middot1 0

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middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

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middot

middotmiddotmiddotmiddot- middot-middotmiddotmiddotmiddotmiddot~middotmiddot middotmiddotmiddot---~---middot--middotmiddot- - middotmiddotmiddot-middot middot- -middot middot-middotmiddotmiddot-middotmiddot~middotmiddot middotmiddot-middotmiddotmiddotmiddotmiddotmiddotmiddotmiddot

k On 922009 consumer VR had_ Rx 495064 fil1~d for 45 hydrocodoneapap

75750 22 DS by Dr D Amos

I On 982009 consumerVR had Rx 495064 filled for 45 hydrocodoneapap

75750 22 DS 16 days early

m On 9212009 consumer VR had Rx 495064 filied for 45 hydroc~doneapap

75750 22 DS 9 days early

n middot On 10122009 consumer VR had Rx 499979 filled for 120 hydrocodoneapap

75750 40 DS by Dr J Greenfield

o On 10192009 consumer VR had Rx 495064 filled for45 hydrocodoneapap

75750 22 DS 33 days early p On 10212009 consumer VR had Rx 503510 filled for 100 hydrocodoneapap

75750 33 DS by Dr M Akhavan 19 ~ays early

q On 1162009 consumer VR had Rx 507006 filled for 30 hydrocodoneapap

75750 30 DS by Dr D Amos 17 days early

r On 11242009 consumer VR had Rx 510363filled for 90 hydrocodoneapap

7575030 DS by Dr M Akhavan 12 days early

s On 1242009 consumer VR had Rx 511575 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall 19 days early

t On 1282009 consumer VR had Rx 512581 filled for 30 hydrocodoneapap

75750 10 DS by Dr J Rojo 26 daysmiddotearly

u On 12102009 consumer VR had Rx 513248 filled for 30 hydrocodoneapap

75750 30 DS by Dr B Chabra 8 days early

v On 12182009 consumer VR had Rx 514733 filled for 90 hydrocodoneapap middot

7575030 DS by Dr G Ma 22 days early

w On 1152010 consumer VR hadRx 519875 filled for 90 hydrocodoneapap

75750 30 DS by Dr F Rundall

x On 1211201 0_ consumer V R had Rx 520810 filled for 50 hydrocodoneapap

75750 12 DS by Dr NAnakwenze 24 days early

30

Accusation I

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

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I

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y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

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e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

2

3

4

5

6

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16

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25

26

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28

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

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28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

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middot 23

24

25

26

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28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

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3

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Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

5

10

15

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25

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-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

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bull

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conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

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middot1 0

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middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

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middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

I middotI

-~--bullmiddotbull-middotmiddot-~--middotmiddot ~~bull -bull - bullbull bull - middotmiddotbullmiddot--middot~middotmiddotmiddotmiddotbull ---~middotmiddot-bullmiddotbullmiddotbull rbullmiddotshy

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y On 1262010 middotconsumer VR had Rx 510818 filled for 50 hydrocodoneapap

75750 12 DS 7 days early

z On 1302010 consumer VR had Rx 520818 filled for 50 hydrocodoneapap

75750 12DS 8 days early

aa On 242010 consumer VR had Rx 523224 filled for 60 hydrocodoneapap

75750 15 DS 7 days early

bb On 2222010 consumer VR hadRx 522650 filled for 60 hydrocodoneapap

75750 30 DS by Dr J Slusher

cc On 2262010 consumer VR had Rx 526671 filled for 60 hydrocodoneapap

75750 30 DS 26 days early

dd On 3112010 consumer VR had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS by Dr J Rojo 27 days early

ee On 392010 consumerVR had Rx 527877 filled for 60 hydtocodoneapap

75750 15 DS 7 days early

ff On 3132010 consumer V R had Rx 527877 filled for 60 hydrocodoneapap

75750 15 DS 11 days early

gg On 3182010 consumer VR had Rx 531783 filled for 60 hydrocodoneapap

75750 15 DS 10 days early

hh On 3292010 consumer VR had Rx 533630 filled for 60 hydrocodoneapap

75750 15 DS

ii On 4520010 consumer VR had Rx 535125 filled for 60 hydrocodoneapap

75750 8 days early

jj On 562010 consumer VR had Rx 541344 filled for 60 hydrocodoneapap

75750 30 DS by Dr D Amos

kk On 5182010 consumer VR had Rx 543672 fill~d for 90 hydrocodoneapap 7 5750

30 DS by Dr M Akhavanim 18 days early

II On 5212010 consumer VR had Rx 544470 filled for 50 hydrocodoneapap

75750 12 DS by Dr N Anakwenzie 27 days early

31 Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

9

10

11

12

13

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25 I

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28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

2

3

4

5

6

7

8

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25

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middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

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

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

25

26

27

28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

mm On 672010 consumer VR hacj Rx 547419 fill~d for60 hydrocodcineapap

75750 30 DS by Dr J Rojo

nn On 6222010 consumer VR had Rx 550599 filled for 90 hydrocodoneapap

751750 3middot0middotD~i by--Dr M Akhavani~ 15 day~ ~~~ly

oo On 7212010 consumer V R had Rx 556218 filled for 90 hydrocodone13-pap

75750 30 DS by Dr G Ma

pp On 7262010 consumer VR had Rx 55733Q filled for 60 hydrocodoneapap middot

75750 30 DS by Dr D Amos 25 days early

qq On 6162010 consumer V~ had Rx 549423 was filled for 100 hydrocodoneapap

10325 50 DS by Dr D Amos

rr On 6242010 consumer VR had Rx 551051 filled for 90 hydrocodoneapap

10325 45 DS 42 days early

ss On 7122010 consumer VR had Rx 554-376 filled for 90 hydrocodoneapap

1032520 DS 27 days early

tt On 10122010 consumer VR had two prescriptions Rx 572546 and Rx 572593

filled for 120 hydromorphone 4 mg for a tota140 DS by Dr D Amos

Prescriptions presented to Rite Aid -Phar-macy 5429 -by customer LR

56 Between july 18 2009 and November 12 2011 Consumer LR went to between 5

and 8 doctors and 17 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

diazepam and hydrocodoneapap-which were filled as follows

a On 1112011 consumer LR had Rx 657799 filled for 30 diazepam 10 mg 30 DS

by Dr J Mays

b middot On 112112011 consumer LR had Rx 661116 filled for 30 diazepam 10 mg 10

days early

c On 192010 consumer LR had Rx 518589 filled for 38 hydrocodoneapap

75750 12 DS by Dr S DelaRosa

d On 11212010 consumer LR had Rx 518589 filled for 22 hydrocodoneapap

75750 9 days early

32

Accusation

-I

1

2

3

4

5

6

7 middot

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25 I

26

27

28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

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

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

25

26

27

28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

-I

1

2

3

4

5

6

7 middot

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25 I

26

27

28

e On 81112011 colsumer LRmiddot had Rx 637099 filled for 35 hydrocodoneapap _ - middot - middot

75750 35 DS byPrJMays

f On 8172011 consumerLR had Rx 638501 filled for25 hydrocodoneapap _ ___ ___

751750 25 DSby Qr S Jeia Rosa 29 days early middotmiddot

Prescriptions prese~ted to Rite Aid Pharmacy 5429 by customer l)R __ middot__ middot middot__ middot- - -~-

57 Consumer nR presented prescriptions to Rite AidPhEl_rmacy 5429 for

acetaminophen-cqql which were filled as follows

a On ~34010 con~umer DR had Rx 526J6 filled for 90 acetaminophen-cod 3

30 DS by DrD Sanchez

middot b On 32212010 consumer DR had Rx 532371 filled for 90 acetaminophen-cod 3

11 days early

c On 672010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

18 DS

d On 6172010 consumer DR had Rx 547239 filled for 150 acetaminophen-cod 3

8 days early

e On 2252011 consumer DR had Rx -599682 filled for 175 acetaminophen-cod 3

58DS

f On 3102011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 43 days early

g On 3152011 consumer DR had Rx 599682 filled for 50 acetaminophen-cod 3

16 DS 9 days early

h On 3222011 consumer DR had Rx 606281 filled for 75 acetaminophen-cod 3

25 DS

i On 3302011 consumer DR had Rx 608355 filled for 175 acetaminophen-cod 3

43 DS 17 days early

j On 4920Tl consumer DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 33 days early

33

Accusation

I middotI

bull 0

middot1

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

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

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

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

25

26

27

28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

I middotI

bull 0

middot1

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

middot

k On 4142011 consurr1er DR had Rx 608355 filled for 50 acetaminophen-cod 3

12 DS 7 days early

middot On 4202011 consumer DR had Rx 608355 flled for 75 acetaminophen-cod 3

6 days early

m On 4252011 consumer DR had Rx 613355 filled for 75 acetaminophen-cod~ 18

DS 13 days early

n On 522011 consumer DR h~d Rx 613355 filled for 175 acetaminophen-cod 3 43

DS 10 days early

o On 592011 consumer DR had Rx 613355 filled for 100 acetaminophen-cod 3

25 DS 34 days early

p On 51820l1 consumer DR had Rx 6184Q6 fill~~ for 175 aceta111inophen-co9 3

43 DS 16 cays eady

q On 5272011 consumer DRhad Rx 618466 middotfilled for 115 acetaminophen-cod 3

34 days early

Prescriptions pr~sented to Rite Aid Pharmacy 5429 by customer AR It bull bull 1 t middot bull I bull bullmiddotbull bull 0 lobull bull 1 bull 1 bull

58 Between June 9 2009 an( J~nuary 2 2012 Consumer AR went to between 4 and 11

doctors apd 8 pharmEJcies and pre$ented prescriptiops to Rite Aid Pharmacy 5429 for

hyctrocodoneap~p Whkh were filled as follows

a On 692010 coilsuirler AR had Rx 547647 fill~d for 90 hycln~cocloneapap

75iso 30 OS by Dr Gqzman

b On 6~92010 consuiper AR had Rx 547647 fiiled for 90 hydrocodoneapap

75750 10 days early

c On 10118201 Q consumer AR had Rx 573 565 filled for 90 hydrocodoneapap middot

7575030 bS by Dr G Lopez

d On 1112010 consumer AR had Rx 573565 filled for 90 hydrocodqne(apap

75750 30 DS 17 days early

e On 11262010 consumer AR had Rx 573565 filled for 90 hydrocodoneapap

7575030 DS

34

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

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

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

25

26

27

28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

ZO

21

22

middot23

24

25

26

27

28

f On 1292010 consumer JR had Rx 573565 filled for 90 hydrocodoneapap

75750 30 DS 17 days early

g On 12262010 consumer AR had Rx 587894 filled for 90 hydrocodoneapap

7575030 DS 13 days early

h On 122011 consumer AIt had Rx 587894 filled for 90 hydrocodoneapap

75750 30 DS 23 days early

i On III 72011 consumer AR had Rx 592578 filled for 100 hydrocodon~apap

75750 33 ps 15 days early

j On 212011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75175033 DS 18 days early

k On 2172011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 17 days early

l On 2282011 consumer AR had Rx 592578 filled for 100 hydrocodoneapap

75750 33 DS 22 days early

m On 3232011 consumer AR had Rx 604495 filled for 100 hydrocodoneapap

75750 33 DS

n On 4132011 consumer AR had Rx 611358 filled for 100 hydrocodoneapap

75750 33 DS 13 days early

o On 522011 cmis]lmer AR had Rx 614887 filled for 100 hydrocodoneapap

7 575033 DS 15 days early

p On 8282011 consumer AR had Rx 629238 filled for 120 hydrocodoneapap

75750 30 DS

q middot On 9142011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

75750 30 DS 11 days early

r On 1072011 consumer AR had Rx 639940 filled for 120hydrocodone(apap

75750 7 days early

s On 10242011 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

7575030 DS 13 days early

35

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

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

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

25

26

27

28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

middot 23

24

25

26

27

28

~-middot -- --middotmiddot middot -- middotmiddot- middot-middot bull

t On 1 J1320 11 consumer AR had Rx 639940 filled for 120 hydrocodoneapap

1snso 30 bsmiddotio ct~ys early

u On 11282011 consumer AR had Rx 664552 filled for 120 hydrocodoneapap

7515o3b b8pound5cl~ysmiddot6arly middot- middotmiddot

v oh ith52011 consumer AR had Rx 670541 filled for 120 hydrocodoneap~p 75750 30 Ps 13 clays early

Prescriptionspr~~ented to Rite Aid Pharmacy 5429 bv customer MS --middot-middotmiddot middot - - _

bullmiddot

59 Cohs~mer MS presented prescriptions to Rite Aid Pharmacy 5429 for alprazolamA~

which were filled as follows

a On 10232010 consumer MS had Rx 57500 I filled for 30 alprazolam 2 mg 15

DS

b On 10242010 consumer MS had Rx 575001 filled for 30 alprazolam 2 mg 15

DS 14 days early

c On 1112010 consumer MS had Rx 578564 filled for 50 alprazolam 2 mg 25 DS

d On 11122010 consumer MS had Rx 578564 filled for 25 alprazolam 12 DS 24

days early

e On 242011 consumer MS had Rx 596633 filledfor 60 alprazolam 2 mg 30 DS

f On 2182011 consumer MS had Rx599561 filled for 60 alprazolam 2 mg 30 DS

16 days early

g On 2252011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 DS

23 days early

h On 2262011 consumer MS had Rx 599561 filled for 30 alprazolam 2 mg 15 Ds

14 days early

i On 10232010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 12 DS

j On 10242010 consumer MS had Rx 575000 filled for 50 hydrocodoneapap

10325 11 days early

36

Accusation

l

I

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

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

25

26

27

28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

l

I

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

Prescriptions presented to Rite Aid Pharmacy 5429 by customer BW

6~~ ~~~een April 10 2oo9 a~d Octdb~r 22 1() 11Tc()~surtier B W ~ went to between 6

and 15 doctors and 14 pharmacies and presented prescriptions to Rite Aid Pharmacy 5429 for

Cionazepam and hydrocodoneapap which were fille8 asfbIbws a On 492009 consumer BW had Rx 468444fllled for 30 clon~epam 2 ing IS DS

by Dr Z Lin

b On 4132009 consumer BW had Rx 468444 filled for 30 clonazepman 2 mg 11

days early

c On 792009 consumer BW had Rx 485094 filled for 30 clonazepam 2 mg 15 DS

d On 7102009 consumer BW had RX 485094 filled for 20 clomizepam 2 mg 10

DS 14 days early

e On 6222010 consumer BW had Rx 550558 filled for 60 clbnazepam 2 mg 30

DS by Dr M Nasir

f On 722010 consumer BW had Rx 552659 filled for 30 Clonazepam 2 mg 15

DS by Dr Z Lin 20 days early

g middotOn 732010 consumer BW had Rx 552659 filled for 30 clonazepam 2 mg 15 DS

14 days early

h On 10142010 consumer BW had Rx 573129 filled for 70 hydrocodoneapap

75750 23 DS by Dr M Nasir

On 102872010 consumer B W had Rx 576119 filled for 90 hydrocodoneiapap

75750 30 DS by Dr I Shah 9 days early

j On 11112010 consumer BW had Rx 578906 filled for 70 hydrocodoneapap

middot 7575035 DS by Dr Nasir21 days early

k On 1232010 consumer BW had Rx 583554 filled for 90 hydrocodoneapap

75750 30 DS 13 day~ early

l On 121620 I0 consumer BW had Rx 5 863 88 filled for 90 hydrocodoneapap

75750 30 DS by Dr I Shah 17 days early

37

Accusation

middotmiddotmiddotmiddot

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

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

25

26

27

28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

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

28

-

middotmiddot -middotmiddot middotmiddotmiddot- --

m On 1282011 consumer BW had Rx 595063 filled for 60 hydrocodoneapap

751750 30 DS by Dr M N~sir

n On 2ll2011 consumer BW had Rx 598142 filled for 90 hydrocodo~eapap

751750 30 Ds by Dr I Shah J6days-eaTy

SECOND CAUSE FOR DISCIPLINE

(Non-Complaint Refilling of Controlled Substance Prescriptions )

(Resp~~dentsRite Aid Pharmacy and Chung)

61 Respondents Rite Aid Pharmacy and Chung are subject to under sections 43 00 and

4301 subdivision (d) and (o) of the Business and Professions Code for unprofessional conduct

for violating Health and Safety Code section 11200 subd (b) in that Respondents refilled

prescriptions more than 5 times and in amount for all refills of that prescription taken together

exceeded a 120-day supply The circumstances are as follows

62 On or about 622010 Rx 544315 filled for 30 triazolam 025 30 DS for Mr RC

and filled on 6302010 7262010 8172010 982010 and 9302010 for 30 triazolam 025 30

DS for total of 150 days supply

63 On 11212011 Rx 663197 filled for 60 hydrocodoneapap 10325 15 DS for Ms

R~P by Dr A Sefa Rx 663197 w~s ~ub_S(qllently refilled by Respondent Rite Aid Pharmacy

5429 as follow On 11232011 for 60 hydrocodoneapap 10325 15 DS on 1222011 for 120

hydrocodoneapap 1032530 DS on 12192011 for 50 hydrocodoneapap 10325 12 DS on

12242011 for 70 hydrocodoneapap 10325 17 DS on 1226~011 for 120 hydrocodoneapap

1032530 DS on 122012 for 50 hydrocodoneapap 10325 12-DS on l92012 for 50

hydrocodoneapap 10325 12 Day and on 1262012 for 20 hydrocodoneapap 10325 5 DS In

total Rx 663197 filled 8 times for a total of 148 days supply

THIRD CAUSE FOR DISCIPLINE

(Non-Compliant Transferring of a Controlled Substance Prescription) ~

(Respondents Rite Aid and Chung)

64 Respondents Rite Aid Pharmacy and Chung are subject to discipline Under sections

4300 and 4301 subdivision (d) and (o) ofthe Business and Professions Code for unprofessional

38

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

25

26

27

28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

5

10

15

20

25

bull

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

conduct for violating title 16 section 1717 subdivision (e) in that Respondent Rite Aid

Pharmacy transferred prescriptions for Schedqle III IV or V controlled substances to another for

refill that didnot include the requisite information required under Title 21 Code ofFederal

Regulaijorts sectfonl30625 The circumstandes were as fcillows

65 On or about Rite Aid Pharmacy 5429 located at 500 S B~ciadway in Los Angeles

CA 90013 transferred prescriptions from ~ther pharmacies on the followi~g dat~s and

prescription_ nu~bers

a A~ t() Rx 491888 d~ted August 17 20Q9 for 120 Norco 75325 for Ms AL a

copy ofthe prescription was faxed from Rite Aid 5345 Portland Oregon It did not contain the

identification of the pharmacist transferring the information the name and address of both

pharmacies the last dispensing date the numb~r ofnfills remaining but not dispensld nor the

number of refills transferred

b As to Rx 550442 dated June 22 2010 for Ms AL for 120 -Hydrocodoneapap

75325 a notation was included that stampted transferred Rx 426595 from 5345 only It did not

contain the identification of the pharmacist transferring the information the name and address of

both phflrmacjes the last dispensing date the n11mber of refills remaining but riot dispensed nor

t~e number of refill tran~ferred

c As to Rx 601131 d~ted Febru~iy 28 2011 for Ms AL for 84 Hydrocodoneapap

75325 a notation stated transferred Rx 42()595 from 5345 only It did not contl)n the

identification ofthe phannacisttransfercingthe information the riarrie and address ofboth

pharmacies the last middotdispensing date the number of refills remaining but not dipensed nor the

rilrhber of refill transferred

d As to Rx 640471 dat~d August 26 io 11 for Ms AL for 120 Hydrocodoneapap

75325 a notation stated transferred Rx 449~99 from 5345 only It did not contain the

ict~ntifi~tion of the pharmacist transferring the information the name and address ofboth

pharmacies the last dispensing date the number of refills remaining but not disp~nsed ~Qr the

number of refills transferred

39

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

25

26

27

28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

I

I middotf

i i I

I I

J I I

1

2

3

4

5

6

7

8

9

middot1 0

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

middot

~~ bull

Ill

Ill

Ill

Ill

e As to Rx 656273 dateci qctber 6 20J 1_ for Ms AL for 84 Hydrocodo~~lapap middotmiddotmiddotmiddot

751325 a notation stated transferred fr~m Rites345 ~~y It dld not contain the Identiflcatio~ of

~he pharmacist transferring the inforrnationt_e_~ameand ~ddress ofboth pharmacies the last

dispensing date the nurriber of ref iis reri1airiirig-buri6fctispbnsed hor-the nimiberCgtfrefiii~- C -- middot middot- middotmiddot-bull middot bull

transferred

FOURTH cAusE _6RnlscifLINE ((onduct that Subverts or Attpriip~~-to S11~Y~ciihj11yestgatiop by the Board )

(Respon~e~~~ff t9fh~r~~6 a~Cry_png)

66 Respondents Rite Aid Pharhiacy ancl Chung are subject to disciplinary action under

section Busiliess and Professions Code secti~n 430 I stlbd (q) for unprofessional conduct in that

Respondents engaged in conduct that subverts or attempts to subvert an investigation ofthe

Board The circumstances are as follows

67 Respondents refused to provide originalprescription documents requested by the

Board in writing dated October 18 20 r2

PRAYER

WHEREFORE Complainant requests that a hearing be held on the matters herein alleged

and that follpwing the hearing the Hoard ofPharmacy issue adecision

1 Revoking or suspending Pharmacy Permit Number PHY 42331 issued to Rite Aid

Pharmacy 5429

2 Revoking or suspending Original Pharmacy License Number RPH 40932 issued to

Anne Chon-Yin Chung aka Anne Chung

middot3 Ordering Rite A1d Pharmacy 5429 to pay the Board ofPharmacy the reasonable

costs ofthe investigation and enforcement ofthis case pursuant to Business and Professions

Code section 1253

40 Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

25

26

27

28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

25

26

27

28

23

24

middotbullmiddot-middotmiddot

4 Ordering Anne Chon-Yin ChuJ1g to pay the Board ofPharmacy the reasonable costs

ofthe inv~stigatio~ and enforcement of this case pursuant to Busil1eSS a~d Pr~fessions Code

section 1253

5 Taking such other and further action as deemed necessary and proper

LA2013509837 51436321docx

GINI Executiv~ middotmiddotmiddot~- ic~r Bo~rCi~pfP11iffii~cy Department of Consumer Affairs Stat~ ofCaJifomia

Complainant

41

Accusation