COMMONWEALTH OF MASSACHUSETTS

SUFFOLK COUNTY	                                                                         BOARD OF REGISTRATION
                                                                                                             IN PHARMACY
	______________________
	                                             )
In the Matter of                    ) 
Angel Khuu                         ) 
PT License No. 10572          ) 
Expiration Date: 10/10/13    )

                                      PHA-2011-0302

	_______________________)

CONSENT AGREEMENT FOR REPRIMAND

The Board of Registration in Pharmacy ("Board") and Angel Khuu ("Registrant"), a Pharmacy Technician employed by the Board, Pharmacy Technician Registration No. 10572, do hereby stipulate and agree that the following information shall be entered into and become a permanent part of the file of Registrant which is maintained by the Board:

1.	The parties enter into this Consent Agreement (“Agreement”) in order to resolve disputed matters arising out of a complaint pending against Registrant before the Board as Docket No. PHA-2011-0302 (“the Complaint”).

2.	Registrant acknowledges that she continued to practice as a Pharmacy Technician from October 10, 2011 to November 8, 2011, at CVS Pharmacy #657, 400 Park Avenue, Worcester, Massachusetts after her Pharmacy Technician Registration had lapsed.

3.	Accordingly, Registrant agrees to the following:

a.	The Registrant’s conduct as described in Paragraph 2 warrants disciplinary action by the Board for violation of G.L. c. 112 § 61 and 247 CMR 8.07(2)(b), 10.03(1)(a) and 10.03(1)(i); and

b.	The Board hereby Reprimands Registrant’s Pharmacy Technician Registration.

4.	The Agreement and its contents shall become a part of the records maintained by the Board, and as such are public records subject to disclosure to the public, other licensing boards, and the National Association of Boards of Pharmacy.

5. 	The Board agrees that in return for the Registrant’s execution of this Agreement, the Board will not advance prosecution of Registrant pursuant to the Complaint; any and all other rights of the Board to take action within the scope of its authority are expressly reserved.

6.	Registrant understands and agrees that her decision to enter into this Agreement and to accept the terms and conditions herein described is a final act and is not subject to reconsideration or judicial review.

7.	Registrant states that she has used legal counsel in connection with her decision to enter into this Agreement, or, if she did not, that she had an opportunity to do so, and that her decision to enter into this Agreement was made of her own free will. 

8.	Registrant certifies that she has read this document entitled “Consent Agreement.” Registrant understands that by executing this Agreement, she is waiving her right to a formal hearing at which she would possess the right to confront and cross-examinee witnesses, to call witnesses, to present evidence, to testify on her own behalf, to contest the allegations, to present oral argument, and to appeal to the courts in the event of an adverse ruling, and to all other rights set forth in the State Administrative  Procedures  Act, G.L. c. 30A, and the  Standard Adjudicatory Rules of Practice and Procedure, 801 CMR 1.01 et seq. 

							Angel Khuu                    
							Registrant (sign and date)

							Margaret Cittadino, M.Ed.
							Associate Director
							Board of Registration in Pharmacy

  March 5, 2013  
 Effective Date 

2