| Probable cause affidavit: |
SUBMITTED BY: CONLEY, STEPHEN 0290 (AR11120104) DID ACQUIRE OR ATTEMPT TO ACQUIRE A CONTROLLED SUBSTANCE, TO WIT: ALPRAZOLAM, A SCHEDULE IV SUBSTANCE; AND CARISOPRODOL, A SCHEDULE IV SUBSTANCE, BY MISREPRESENTATION, FRAUD, FORGERY, DECEPTION OR SUBTERFUGE, IN VIOLATION OF FLORIDA STATUTE 893.13(7)(A)9; AND DID KNOWINGLY SELL, PURCHASE, DELIVER OR BRING INTO THIS STATE, OR DID KNOWINGLY HAVE IN HER ACTUAL OR CONSTRUCTIVE POSSESSION A CONTROLLED SUBSTANCE, TO WIT: HYDROCODONE OR ANY SALT, DERIVATIVE, ISOMER, OR SALT OF AN ISOMER, IN AN AMOUNT OF APPROXIMATELY ONE HUNDRED GRAMS, IN VIOLATION OF FLORIDA STATUTE 893.135(1)(C)1C. ON 040411, MYSELF AND DEPUTY SMITH WERE DISPATCHED TO THE WALGREENS PHARMACY IN HOMOSASSA SPRINGS, IN REFERENCE TO A FRAUDULENT OR ALTERED PRESCRIPTION. THE INFORMATION RECEIVED WAS THAT THE DEFENDANT, MS APRIL COOPER, HAD ATTEMPTED TO PASS A PRESCRIPTION OF ALPRAZOLAM. THE ORIGINAL PRESCRIPTION WAS FOR NINETY PILLS, HOWEVER A ONE HAD BEEN PLACED IN FRONT OF THE NINE, MAKING THE PRESCRIPTION FOR ONE HUNDRED NINETY PILLS. THE PHARMACIST ON DUTY CONTACTED THE DOCTOR THAT HAD WRITTEN THE PRESCRIPTION AND VERIFIED THAT IT HAD BEEN ALTERED. UPON MY ARRIVAL, I CONTACTED THE PHARMACIST, WHO ADVISED THAT THE DEFENDANT WAS PARKED IN THE DRIVE THRU WAITING ON THE PRESCRIPTION. HE ADVISED THAT THE PERSON THAT TRIED TO PASS THE ALTERED PRESCRIPTION WAS IN THE DRIVER SEAT AND ANOTHER WHITE FEMALE WAS IN THE PASSENGER SEAT, WHO CAME INTO THE STORE AS WELL. I ADVISED THE PHARMACIST TO TELL THEM TO COME INSIDE THE STORE WHILE I WAITED TO MAKE CONTACT. AS THE DEFENDANT PULLED AROUND THE STORE AND INTO THE PARKING LOT, I PULLED MY VEHICLE BEHIND IT AND MADE CONTACT WITH THE DRIVER, IDENTIFIED AS DEFENDANT KAISER. DEFENDANT COOPER WAS SEATED IN THE FRONT PASSENGER SEAT. DEFENDANT KAISER WAS ASKED TO STEP OUT OF THE VEHICLE, WHICH SHE DID AND WALKED TO DEPUTY COX'S PATROL VEHICLE. I ADVISED THAT I WAS INVESTIGATING A NARCOTICS VIOLATION AND THAT SHE WOULD BE DETAINED WHILE I CONTINUED THAT INVESTIGATION. AT THAT TIME, DEFENDANT KAISER BACKED AWAY FROM ME AND DEPUTY COX, STATING THAT SHE WOULD NOT BE DETAINED. I THEN GRABBED DEFENDANT KAISER BY HER RIGHT WRIST, WHICH SHE CONTINUED TO PULL AWAY. DEFENDANT KAISER WAS THEN RESTRAINED AND PLACED IN HANDCUFFS BEHIND HER BACK. DEPUTY SMITH STOOD BY WHILE I ENTERED THE WALGREENS STORE AND MADE CONTACT WITH THE PHARMACIST, WHO PROVIDED ME WITH THE ALTERED PRESCRIPTION. THE PHARMACIST ALSO ADVISED THAT WHEN THE DEFENDANTS DROPPED OFF THE ALTERED PRESCRIPTION, THEY THEN WENT TO THE WALGREENS PHARMACY IN SUGARMILL WOODS, AND FILLED HYDROCODONE AND CARISOPRODOL, BOTH OF WHICH ARE CONTROLLED SUBSTANCES. I THEN CONTACTED THE DOCTOR LISTED ON THE PRESCRIPTION, WHO ADVISED THAT THE PRESCRIPTION HAD BEEN ALTERED AND DEFENDANT COOPER WAS NOT AUTHORIZED TO CHANGE THE AMOUNT OF PILLS ON THE PRESCRIPTION FORM. I ASKED IF THE DOCTOR WAS AWARE OF DEFENDANT COOPER BEING A PATIENT AND RECEIVING CONTROLLED SUBSTANCES FROM OTHER DOCTORS. I WAS ADVISED THAT THE DOCTOR DID NOT HAVE KNOWLEDGE OF DEFENDANT COOPER SEEING ANY OTHER DOCTORS AND RECEIVING CONTROLLED SUBSTANCES OF LIKE THERAPEUTIC USE. I THEN RETURNED AND MADE CONTACT WITH DEFENDANT COOPER. DURING A POST MIRANDA, DIGITALLY RECORDED INTERVIEW I ASKED DEFENDANT COOPER ABOUT THE ALTERED PRESCRIPTION. SHE STATED THAT SHE DID NOT DO IT AND THAT IT MUST HAVE BEEN DEFENDANT KAISER. SHE STATED THAT SHE STAYED IN THE VEHICLE WHEN THE DEFENDANT KAISER WENT INSIDE THE PHARMACY TO FILL THE PRESCRIPTION. SHE STATED THAT THEY WENT TO WAL MART AND SHOPPED WHILE THEY WAITED. DEFENDANT COOPER FAILED TO MENTION THAT THEY WENT TO THE OTHER WALGREENS AND FILLED OTHER CONTROLLED SUBSTANCES THERE. SHE ALSO INITIALLY PROVIDED ME WITH A FALSE FIRST NAME, STATING HER NAME WAS TRACY COOPER. THESE DECEPTIVE REMARKS WERE LATER CHALLENGED AND SHE ADMITTED HER REAL NAME AND STATED SHE WAS SCARED TO MENTION SHE GOT OTHER PILLS FROM THE OTHER WALGREENS. DEFENDANT COOPER STATED THAT THE OTHER PILLS SHE HAD FILLED WERE IN HER PURSE AND THAT I COULD INSPECT THEM. DEFENDANT COOPER WAS LATER ARRESTED AND A SEARCH OF THE VEHICLE AND HER PURSE REVEALED THE FOLLOWING: AN AMBER BOTTLE CONTAINING ONE HUNDRED HYDROCODONE/APAP 10/500 MG TABLETS FILLED ON THIS DATE FROM DOCTOR NG. AN AMBER BOTTLE CONTAINING SIXTY CARISOPRODOL 350 MG TABLETS FILLED ON THIS DATE FROM DOCTOR NG. AN EMPTY AMBER BOTTLE LABELED OXYCODONE 30 MG TABLET FILLED ON 03312011. THIS PRESCRIPTION WAS WRITTEN BY DOCTOR GROVER. AN AMBER BOTTLE CONTAINING FORTY NINE BUTALB/APAP/CAF 50-325-40 FILLED ON 03312011 BY DOCTOR GROVER. ALL PRESCRIPTION BOTTLES WERE LABELED WITH THE NAME APRIL COOPER. ALSO LOCATED IN DEFENDANT COOPER'S PURSE WAS A SINGLE SHEET OF PAPER WITH NAMES, SLANG NAMES OF DRUGS AND MONEY, WHICH IS INDICATIVE OF A DRUG LEDGER. BASED ON THE FACT THAT DEFENDANT COOPER WAS INVOLVED IN ALTERING PRESCRIPTIONS FOR CONTROLLED SUBSTANCES, WITHHOLDING INFORMATION FROM HER PRACTITIONERS REGARDING HER OBTAINING CONTROLLED SUBSTANCES FROM OTHER DOCTORS, HAVING IN HER POSSESSION WHAT APPEARS TO BE A DRUG LEDGER, AND HAVING IN HER POSSESSION ONE HUNDRED HYDROCODONE PILLS THAT WERE ACQUIRED BY FRAUD, SHE WAS ARRESTED AND CHARGED WITH TRAFFICKING IN HYDROCODONE. SHE WAS ALSO CHARGED WITH TWO COUNTS OF ACQUIRING A CONTROLLED SUBSTANCE BY FRAUD AS IT RELATES TO HER ACQUIRING THE ARISOPRODOL AND ATTEMPTING TO ACQUIRE THE ALPRAZOLAM WITH AN ALTERED PRESCRIPTION. THE HYDROCODONE PILLS LATER WEIGHED APPROXIMATELY ONE GRAM EACH, MAKING THE TOTAL WEIGHT OF THE PILLS APPROXIMATELY ONE HUNDRED GRAMS, NOT INCLUDING THE BOTTLE. DEFENDANT COOPER WAS TRANSPORTED TO THE CITRUS COUNTY DETENTION FACILITY BY DEPUTY CHENOWETH. BOND SET AT $510,000.00 PER THE BOND SCHEDULE. "If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact the ADA Coordinator at the Office of the Trial Court Administrator, Citrus County Courthouse, 110 North Apopka Avenue, Inverness, Florida 34450, Telephone (352) 341-6700, at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711.” *NOT-EXEMPT* |
