| Probable cause affidavit: |
SUBMITTED BY: CONLEY, STEPHEN 0290 (AR11119892) THE DEFENDANT, MS PATSY ROAN, DID ACQUIRE OR OBTAIN OR ATTEMPT TO ACQUIRE OR OBTAIN A CONTROLLED SUBSTANCE, TO WIT: OXYCODONE AND MORPHINE, BY MISREPRESENTATION, FRAUD, FORGERY, DECEPTION, OR SUBTERFUGE IN VIOLATION OF FLORIDA STATUTE 893.13(7)(A)9. ON 03152011, IT WAS REPORTED TO THE CITRUS COUNTY SHERIFFS OFFICE THAT THE DEFENDANT, MS PATSY ROAN, WAS DOCTOR SHOPPING AND ACQUIRING CONTROLLED SUBSTANCES THROUGH DECEPTION AND WITHHOLDING INFORMATION FROM HER PRACTITIONER. IN THE INITIAL COMPLAINT, DOCTOR BOWDEN ADVISED THAT HE PRESCRIBED DEFENDANT ROAN PERCOCET AND MORPHINE AND THAT HE LEARNED SHE WAS ALSO RECEIVING OXYCODONE FROM THE TAMPA PAIN CLINIC. DOCTOR BOWDEN ADVISED THAT HE DID NOT KNOW DEFENDANT ROAN WAS RECEIVING THE MEDICATION FROM THE TAMPA PAIN CLINIC AND THAT SHE WITHHELD THAT INFORMATION FROM HIM. ON 032111, I BECAME AWARE OF THIS COMPLAINT AND CONTACTED B&W REXALL DRUGS AND THEY CONFIRMED THE FOLLOWING PRESCRIPTION FILLS FOR DEFENDANT ROAN: ON 082710, THE DEFENDANT RECEIVED 90 MORPHINE SULFATE TABLETS FROM DOCTOR BOWDEN. ON 082710, THE DEFENDANT RECEIVED 120 PERCOCET TABLETS FROM DOCTOR BOWDEN. ON 082710, THE DEFENDANT RECEIVED 150 OXYCODONE TABLETS FROM DOCTOR MUBANG. ON 092310, THE DEFENDANT RECEIVED 90 MORPHINE SULFATE TABLETS FROM DOCTOR BOWDEN. ON 092310, THE DEFENDANT RECEIVED 120 PERCOCET TABLETS FROM DOCTOR BOWDEN. ON 092410, THE DEFENDANT RECEIVED 150 OXYCODONE TABLETS FROM DOCTOR MONTOYA. ON 102110, THE DEFENDANT RECEIVED 90 MORPHINE SULFATE TABLETS FROM DOCTOR BOWDEN. ON 102110, THE DEFENDANT RECEIVED 120 PERCOCET TABLETS FROM DOCTOR BOWDEN. ON 102210, THE DEFENDANT RECEIVED 150 OXYCODONE TABLETS FROM DOCTOR MONTOYA. ON 111810, THE DEFENDANT RECEIVED 90 MORPHINE SULFATE TABLETS FROM DOCTOR BOWDEN. ON 111810, THE DEFENDANT RECEIVED 180 PERCOCET TABLETS FROM DOCTOR BOWDEN. ON 111810, THE DEFENDANT RECEIVED 150 OXYCODONE TABLETS FROM DOCTOR MONTOYA. ON 121610, THE DEFENDANT RECEIVED 180 PERCOCET TABLETS FROM DOCTOR BOWDEN. ON 121610, THE DEFENDANT RECEIVED 90 MORPHINE SULFATE TABLETS FROM DOCTOR BOWDEN. ON 121610, THE DEFENDANT RECEIVED 150 OXYCODONE TABLETS FROM DOCTOR MONTOYA. ON 121610, THE DEFENDANT RECEIVED 90 ALPRAZOLAM TABLETS FROM DOCTOR MERCED. ON 011211, THE DEFENDANT RECEIVED 180 PERCOCET TABLETS FROM DOCTOR BOWDEN. ON 011311, THE DEFENDANT RECEIVED 90 MORPHINE SULFATE TABLETS FROM DOCTOR BOWDEN. ON 011311, THE DEFENDANT RECEIVED 150 OXYCODONE TABLETS FROM DOCTOR MERCED. ON 021011, THE DEFENDANT RECEIVED 180 PERCOCET TABLETS FROM DOCTOR BOWDEN. ON 021011, THE DEFENDANT RECEIVED 90 MORPHINE SULFATE FROM DOCTOR BOWDEN. ON 021011, THE DEFENDANT RECEIVED 150 OXYCODONE TABLETS FROM DOCTOR BOWDEN. 030911, THE DEFENDANT RECEIVED 180 PERCOCET TABLETS FROM DOCTOR BOWDEN. ON 030911, THE DEFENDANT RECEIVED 90 MORPHINE SULFATE TABLETS FROM DOCTOR BOWDEN. ON 031011, THE DEFENDANT RECEIVED 150 OXYCODONE TABLETS FROM DOCTOR MERCED. ON 032111, I CONTACTED DOCTOR BOWDEN'S OFFICE AND FAXED A DOCTOR SHOPPING AFFIDAVIT WHICH WAS RETURNED BY "FAX" INDICATING DEFENDANT ROAN FAILED TO DOCUMENT THE FACT THAT SHE WAS SEEING OTHER PHYSICIANS AND THAT SHE SPECIFICALLY ASKED FOR CONTROLLED SUBSTANCES PRESCRIBED. ON 032211, DEPUTY BERGEN AND I RESPONDED TO THE RESIDENCE OF DEFENDANT ROAN TO DISCUSS THE DOCTOR SHOPPING ISSUE. IT WAS LATER AGREED TO MEET DEFENDANT ROAN THE FOLLOWING DAY AT THE CITRUS COUNTY DETENTION FACILITY FOR A FOLLOW UP INTERVIEW. ON 032311, DEPUTY BERGEN AND I MET WITH DEFENDANT ROAN AT THE CITRUS COUNTY DETENTION FACILITY. AT THAT TIME A DIGITALLY RECORDED, POST MIRANDA, INTERVIEW WAS CONDUCTED WHERE DEFENDANT ROAN ADMITTED TO GOING TO MULTIPLE DOCTORS AND RECEIVING CONTROLLED SUBSTANCES FROM BOTH DOCTOR BOWDEN AND THE TAMPA PAIN CLINIC WITHOUT ADVISING THEM SHE WAS RECEIVING OTHER PRESCRIPTIONS OF LIKE THERAPEUTIC USE. AT THE CONCLUSION OF THE INTERVIEW, DEFENDANT ROAN WAS ARRESTED AND CHARGED WITH ONE COUNT OF ACQUIRING A CONTROLLED SUBSTANCE BY FRAUD AND RELEASED ON HER OWN RECOGNIZANCE. ALL PAPERWORK AND THE DIGITAL RECORDING WERE LATER TURNED IN TO EVIDENCE. CASE CLOSED. "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* |
