| Probable cause affidavit: |
SUBMITTED BY: BERGEN, JOHN 0519 (AR11122877) DID ATTEMPT TO OBTAIN A CONTROLLED SUBSTANCE BY FRAUD, TO WIT: BY USE OF A FRAUDULENT PRESCRIPTION FOR ADDERELL (A SCHEDULE TWO NARCOTIC) AND SUBUTEX (A SCHEDULE THREE NARCOTIC), IN VIOLATION OF FLORIDA STATE STATUTE, 893.13(7)(A)9. ON 091411 I WAS CONTACTED BY THE PHARMACY MANAGER, CHRIS MANN, AT THE CVS PHARMACY LOCATED AT 602 WEST MAIN STREET IN INVERNESS. UPON ARRIVAL, I MADE CONTACT WITH CVS PHARMACY MANAGER, CHRIS MANN. HE EXPLAINED THAT THE PREVIOUS EVENING A FEMALE BY THE NAME OF MS KRISTIN NELSON CAME IN AND DROPPED OFF TWO FRAUDULENT PRESCRIPTIONS. HE PROVIDED ME WITH THE ORIGINAL PRESCRIPTIONS, HOWEVER, HE TOLD ME THE PHARMACIST WHO WAS ON DUTY AND TOOK THEM WAS NOT AT THE STORE AND WOULD NOT RETURN UNTIL THE FOLLOWING DAY. ON 092211, I RESPONDED BACK TO THE CVS PHARMACY AND SPOKE WITH AMY SCHNEIDER (WITNESS) WHO EXPLAINED THAT KRISTIN NELSON HAD DROPPED OFF THE TWO FRAUDULENT PRESCRIPTIONS IN THE DRIVE THROUGH TO ONE OF THE PHARMACY TECHNICIANS. WHEN SHE GOT THE PRESCRIPTIONS AND BEGAN TO FILL THEM, SHE NOTICED THE ENTIRE PRESCRIPTION INCLUDING THE DOCTOR'S SIGNATURE WAS A PHOTOCOPY. SHE ADVISED SHE DID NOT FILL THE PRESCRIPTION AND WAITED UNTIL THE FOLLOWING MORNING TO CALL THE DOCTOR. SHE THEN SPOKE TO DOCTOR CHOUDRY WHO EXPLAINED THAT THOSE PRESCRIPTIONS WERE NOT VALID, AND THAT SHE HAD BEEN DISCHARGED FROM HIS PRACTICE IN JULY OF 2011 FOR FAKING OTHER PRESCRIPTIONS AS WELL AS FOR CREDIT CARD FRAUD. THE TELEPHONE NUMBER ON THE PRESCRIPTION THAT MS NELSON TRIED TO PASS IS DISCONNECTED AND WAS ASSOCIATED WITH DOCTOR CHOUDRY'S OLD OFFICE. MS SCHNEIDER THEN RAN A PRESCRIPTION PROFILE FOR OTHER CVS LOCATIONS WHICH SHOWED MS NELSON HAD PASSED THE SAME PRESCRIPTIONS IN WILDWOOD ON 092011. SHE ALSO THEN CONTACTED THE WILDWOOD POLICE. AT that TIME I SPOKE WITH MS ASHLEY ANDERSON, WHO IS THE PHARMACY TECHNICIAN THAT TOOK THE PRESCRIPTION. SHE ADVISED THAT SHE OBSERVED KRISTIN NELSON IN A SMALL SILVER SUV IN DRIVE LANE NUMBER TWO. BOTH THE PHARMACIST TECHNICIAN AND THE PHARMACIST PROVIDED SWORN WRITTEN STATEMENTS WHICH WERE TURNED IN TO RECORDS. UPON OBSERVING THE PRESCRIPTIONS MYSELF, I NOTICED THEM TO BE CLEARLY PHOTOCOPIED ALONG WITH THE DOCTOR'S SIGNATURE. THE DATE ON THE THE PRESCRIPTION WAS 071611. ONE PRESCRIPTION WAS FOR ADDERELL (A SCHEDULE TWO NARCOTIC) AT 30 MILLIGRAMS. the OTHER WAS FOR SUBUTEX (A SCHEDULE THREE NARCOTIC) AT 8 MILLIGRAMS. ON 092311 I MADE CONTACT WITH MS NELSON AT HER RESIDENCE. I BEGAN A DIGITALLY TAPED INTERVIEW AND THEN READ HER MIRANDA RIGHTS FROM A PRE-PRINTED AGENCY CARD. WHEN I PRESENTED HER WITH ALL THE FACTS OF THE CASE, SHE EXPLAINED THAT SHE DOES SOMETIMES PHOTOCOPY PRESCRIPTIONS, BUT ONLY TO HAVE A RECORD OF THEM FOR HERSELF. SHE ADVISED IF SHE TURNED IN A PHOTOCOPIED PRESCRIPTION, IT MUST HAVE BEEN A MISTAKE, SHE FURTHER EXPLAINED IT IS very DIFFICULT FOR HER TO FIND A DOCTOR WHO WILL WRITE HER PRESCRIPTIONS FOR THE MEDICATIONS. UPON FURTHER QUESTIONING ABOUT TURNING IN THE PRESCRIPTIONS, SHE ADVISED THAT SHE WANTED TO SPEAK TO AN ATTORNEY. I THEN STOPPED THE INTERVIEW. AS SOON AS I SHUT OFF MY RECORDER, MS NELSON STATED, "SO, WHAT IF I TELL YOU THAT I DID IT AND MADE A MISTAKE?". I THEN TURNED MY RECORDER BACK ON AND DOCUMENTED WHAT SHE HAD SAID. I DID NOT ASK HER ANY FURTHER QUESTIONS AND SHE AGAIN REQUESTED AN ATTORNEY. AT THAT TIME THE INTERVIEW WAS CONCLUDED AND THE DEFENDANT WAS PLACED UNDER ARREST FOR ONE COUNT OF OBTAINING A CONTROLLED SUBSTANCE BY FRAUD. THE DEFENDANT WAS HANDCUFFED AND PLACED IN THE REAR OF MY PATROL VEHICLE AND TRANSPORTED TO THE CITRUS COUNTY DETENTION FACILITY FOR BOOKING AND PROCESSING WITHOUT INCIDENT. . UPON ARRIVAL AT THE DETENTION FACILITY, THE DEFENDANT'S BOND WAS SET AT $2,000.00 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* |
