STATE OF VERMONT SECRETARY OF STATE OFFICE OF PROFESSIONAL REGULATION VETERINARY BOARD STIPULATION AND CONSENT ORDER STIPULATION.

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1 SECRETARY OF STATE OFFICE OF PROFESSIONAL REGULATION VETERINARY BOARD IN RE: ROBIN KERR! SOLOMON, D.V.M. License No Docket No: VEO STIPULATION AND CONSENT ORDER STIPULATION NOW COMES the State ofvennont, through State, Robert H. Backus, and the Respondent, Robjn Kern Solomon, D. V.M, along with her attorney, Ritchie E. Berger. Esq., who stipulate and agree as follows: Board Authority 1 The Vermont State Veterinary Board ("the Board" has authority to issue warnings or reprimands, suspend, revoke, limit, condition current licenses, or prevent the renewal of lapsed licenses if, after disciplinary hearing, the Board finds that the Respondent has engaged in unprofessional conduct. 3 V.S.A. 129, 129(a and 814{d; 26 V.S.A and 2431; Administrative Rules of the Veterinary Board; and the Rules of the.. Statement of Facts 2 The Respondent, Robin Kern Solomon, is licensed as a Vetennarian by the State of Veffilont under License Number The Respondent's license was originally issued on November 22, 1996 and has a current expiration date of May 31, At all times relevant, the Respondent was employed as the veterinarian at Brown Animal Hospital ("BAH" located in South Burlington, Vermont. 4 On January 12, 2005, the Respondent admitted to State Investigator Brenda Tetrault that she began diverting the drug Buprenorphine from BAR in small amounts in March By way of infoffilation, Buprenorphine is a thebaine derivative, used in animals as an analgesic. 6 In March 2004, a vial of Buprenorphine was missing from BAR. The vial was located in the Respondent's pocket during a search by the Regional Medical Director. The Respondent admitted to Investigator Tetrault that she had taken the Buprenorphine for selfmedication. Montpelier, VT

2 7 On May 31,2004, the Respondent diverted 10 ml ofbuprenorphine from BAR. 8 In August 2004, a co-worker observed the Respondent taking a vial ofbuprenorphine. When confronted about this by the BAR Medical Director, the Respondent admitted to having diverted Buprenorphine from BAR. Charges 9 By committing the act(s and/or omission(s alleged above, the Respondent has committed unprofessional conduct in that the Respondent has violated: i. 3 V.S.A. 129a(b (2 (Failure to practice competently by reason of any cause on a single occasion or on multiple occasions may constitute unprofessional conduct. Failure to practice competently includes failure to confoml to the essential standards of acceptable and prevailing practice; and ii. 3 V.S.A. 129a(a(3 (Failing to comply with the provisions of federal or state statutes or rules governing the practice of the profession. Understandings 10 Respondent understands that the Veterinary Board must review and accept the terms of the Consent Order. If the Board rejects any portion, the entire Stipulation and Consent Order shall be null and void. 11 Respondent specifically waives any claims that any disclosures made to the full Board during its review of this agreement have prejudiced her rights to a fair and impartial hearing in future hearings if this agreement is not accepted by the Board. 12 Respondent has read and reviewed this entire document and agrees that it contains the entire agreement between the parties. 13 Respondent is not under the influence of any drugs or alcohol at the time she signs this Stipulation and Consent Order. 14 Respondent voluntarily enters into this agreement after the opportunity to consult with legal counsel and is not being coerced by anyone into signing this Stipulation and Consent Order. 15 Respondent voluntarily waives her right to a contested hearing before the Veterinary Board and any right to appeal from the order entered pursuant to this stipulation. 16 Respondent agrees that the Order set forth below may be entered by the Board. ORDER Montpelier. VT Based on the Stipulation above, it is ORDERED AND ADJUDGED as follows:

3 A. Respondent's actions described above demonstrate grounds for discipline because the Respondent committed unprofessional conduct in violation of: i. 3 V.S.A. l29a(b (2 (Failure to practice competently by reason of any cause on a single occasion or on multiple occasions may constitute unprofessional conduct. Failure to practice competently includes failure to conform to the essential standards of acceptable and prevailing practice; and ii. 3 V.S.A. 129a(a(3 (Failing to comply with the provisions of federal or state statutes or rules governing the practice of the profession. B. The Veterinary Board hereby REPRIMANDS Respondent and suspends her license for ten days, with credit of ten days. Her license is CONDITIONED for THREE (3 YEARS commencing with the date of entry of this Stipulation and Consent Order. The conditions are as follows: (1 Issuance of License. Upon the commencement of these conditions, Respondent shall be issued a license labeled "conditioned." (2 Completion of Drug Abuse Counseling and Treatment Plan. Respondent shall enter into and continue in drug abuse counseling with a treating professional approved by the Board until the treating professional shall certify in writing to the Veterinary Board that such counseling is no longer necessary. Respondent shall participate in any counseling, therapy or treatment, including programs like Narcotics Anonymous, recommended by her treating professional. Dr. Suzanne R. Parker is approved by the Board. Once the treating professional certifies that counseling is no longer necessary Respondent may petition to have the conditions removed from her license. (3 Notification to Treating Professional. Respondent shall provide a copy of this Stipulation and Consent Order to her treating professional and cause her treating professional to infonn the Board, in writing and on professional letterhead, of receipt of the Stipulation and Consent Order and the treating professional's ability to comply with the conditions related to treatment and with all other tends of this Consent Order. Montpelier. VT (4 R~orts from Treating Professional. Respondent shall authorize and cause her treating professional to submit to the Board evidence of satisfactory participation in the treatment plan. These reports shall be submitted in writing on professional letterhead. The first report is due one month after the date of the entry of this order. Subsequent reports are due quarterly for one year and then every six months for two years. Should a problem with the Respondent's adhering to the treatment plan arise, the treating professional shall submit a report to the Board immediately. Respondent shall authorize her treating professional to provide all information requested by the Veterinary Board, either Qrally or in writing, at any time during the period this

4 Consent Order is in effect. The infoffilation requested may include that necessary to establish participation in and engagement in treatment but shall not go to the substance of the treatment sessions. (6 Notification to Em!>loyers. Respondent shall provide a copy of this Stipulation and Consent Order to all employers in any current or future setting during the conditioned period in which Respondent practices as a veterinarian and inform them of Respondent's conditional license status. Within ten (10 days of the commencement of the conditions and of any subsequent veterinary employment, Respondent shall cause Respondent's employer to write to the Board, on the employer's letterhead, acknowledging receipt of the Stipulation and Consent Order. (8 Abstain from Drug Use. Respondent shall abstain completely from the consumption or possession of regulated drugs with the exception of prescribed medications. {9 Drug Use Exc~tion. Respondent shall not take controlled substances unless necessary. Respondent may take scheduled/controlled medications lawfully prescribed for a bona fide illness or condition by a physician, dentist, or nurse practitioner. Respondent shall inform her treating professional of all medications she is taking, including over the counter. (10 Random Drug Testing. Respondent shall submit to random drug screenings at the request of the Respondent's treating professional. All testing shall be done on a random, unannounced basis (11 Notification of Place of Emulovrnent/Personal Address/Teleuhone Number. Within five (5 days of the date of entry of this Consent Order, Respondent shall notify the Board, in writing, of her current place of employment, personal address, and telephone number. Respondent shall further notify the Board, in writing, within five (5 days of any change in employment, personal address, or telephone number. (12 Notification to Other States. In the event that the Respondent is licensed as a veterinarian in any other state( s, she must inform the veterinary licensing board of the state(s in which the Respondent is licensed of the conditional status of her Vermont veterinary license within thirty (30 days of the date of entry of this Order. If the Respondent fails to provide such notification, it will be considered a violation of this Order. (13 License Renewal.. If the Respondent's license expires while this Order is still in effect, this Order does not automatically extend the license. In that situation, in order to continue to practice as a veterinarian, the Respondent must timely apply for renewal, pay the applicable fee and demonstrate that she has otherwise complied with the requirements for license renewal. Montpelier, VT

5 (14~ The Respondent shall bear all costs of complying with this Consent Order. (15 Violation of this Order. If the Respondent violates the tenns of this Order in any respect, the Board, after giving the Respondent notice and an opportunity to be heard, may rescind or modify this Order and impose additional appropriate disciplinary actions. If a complaint of unprofessional conduct is made against the Respondent during the tenn of this Order, this Order shall be automatically extended until the unprofessional conduct matter is concluded. C. Notwithstanding any provision above, the Respondent must continue to meet all Veterinary Board requirements for maintaining a license, license renewal and license reinstatement. D. This Stipulation and Consent Order is a matter of public record and may be reported to other licensing authorities as provided in 3 V.S.A. 129(a. E. This Stipulation and Consent Order will remain part of Respondent's licensing file and may be used for purposes of determining sanctions in any future disciplinary matter. AGREED TO: Dated: By: ~(,~~ ~,4(~ Robin Kern Solomon APPROVED AND SO ORDERED: VERMONT STATE VETERINARY BOARD Montpelier, VT

6 Dated: ~ lit Ib~ By: Date of Entry: R L } z. L OSve.solornon.stip Montpelier, VT

7 SECRETARY OF STATE OFFICE OF PROFESSIONAL REGULATION VETERINARY BOARD IN RE: ROB1N KERR! SOLOMON, D.V.M. License No Docket No: VEO SPECIFICATION OF CHARGES NOW COMES the State ofvennont and makes the following Charges against the Respondent, RobinKerri Solomon, D.V.M.: Board Authority 1 The Vernlont State Veterinary Board ('~e Board" has authority to issue warnings or reprimands, suspend, revoke, limit, condition current licenses, or prevent the renewal of lapsed licenses if, after disciplinary hearing, the Board finds that the Respondent has engaged in unprofessional conduct. 3 V.S.A..129, 129(a and 814(d; 26 V.S.A and 2431; Administrative Rules of the Veterinary Board; and the Rules of the. Statement of Facts 2 The Respondent, Robin Kerri Solomon, is licensed as a Veterinarian by the State of Vermont under License Number The Respondent's license was originally issued on November 22, 1996 and has a current expiration date o-fmay 31, At all times relevant, the Respondent was employed as the veterinarian at Brown Animal Hospital ("BAH" located in South Burlington, Vermont. 4 On January 12, 2005, the Respondent admitted to State Investigator Brenda Tetrault that she began diverting the drug Buprenorphine from BAR in small amounts in March By way of infomlation, Buprenorphine is a thebaine derivative, used in animals as an analgesic. 6 In March 2004, a vial ofbupreno~hine was missing from BAR. The vial was located in the Respondent's pocket during a search by the Regional Medical Director. The Respondent admitted to Investigator Tetrault that she had taken the Buprenorphine for selfmedication. 7 On May 31, 2004, the Respondent diverted 10 m1 ofbuprenorphine from BAR. Montpelier. VT

8 8 In August 2004, a co~worker observed the Respondent taking a vial ofbuprenorphine. When confronted about this by the BAR Medical Director, the Respondent admitted to having diverted Buprenorphine from BAR. Charges 9 By committing the act(s and/or omission(s alleged above, the Respondent has committed Unprofessional conduct in that the Respondent has violated: i. 3 V.S.A. 1 29a(b (2 (Failure to practice competently by reason of any cause on a single occasion or on multiple occasions may constitute unprofessional conduct. Failure to practice competently includes failure to confonn to the essential standards of acceptable and prevailing practice; and ii. 3 V.S.A. 1 29a(a(3 (Failing to comply with the provisions of federal or state statutes or rules governing the practice of the profession. Relief Requested WHEREFORE, the license of Robin Kern Solomon should be revoked, suspended, r~rimanded, conditioned or otherwise disciplined. Dated at Montpelier, V ermont this~~;~.4;;;;:!!!!.5-'- By: OF State Prosecuting Montpelier. VT