STATE OF ILLINOIS DEPARTMENT OF FINANCIAL AND PROFESSIONAL REGULATION DIVISION OF PROFESSIONAL REGULATION DIVISION OF PROFESSIONAL REGULATION ) OF THE ILLINOIS DEPARTMENT OF FINANCIAL ) AND PROFESSIONAL REGULATION, Complainant, ) v. ) Case No. 2018-02364 Animal Welfare League, ) License No. 228.000029, ) License No. 228.000030, ) CS License No, 320MM, & ) CS License No. 32)29, Respondent ) CONSENT ORDER The Division of Professional Regulation of the Illinois Department of Financial and Professional Regulation (“Department”), by Department Attomey Vaughn G. Bentley, and Respondent Animal Welfare League (“Respondent”), by its attomey Priyanka Desai of Goldberg Law Group, LLC, agree to the following: STIPULATIONS Respondent holds Illinois certified euthanasia agency license nos. 228,000029 and 228,000030, and certified euthanasia agency controlled substance license nos. 32MNEPS and 3B, all of which are ‘currently in active status. On or about February 27, 2018, a Department investigator conducted an inspection ‘of Respondent's facility located at 1030S Southwest Hwvy, Chicago Ridge, Illinois. The Department investigator noted several potential violations of the Humane Euthanasia in Animal Shelters Act, including Violations of the Ilinois and Federal Controlled Substances Act and aiding certified euthanasia technicians and unlicensed individuals in violating provisions of the Humane Euthanasia in Animal Shelters Act. A second inspection showed that many of the violations had been cured. The allegations as set forth herein would constitute grounds for the Department to discipline Respondents licenses pursuant to $10 ILCS 72/65(4) and (5), 68 IAC 1248.40, 68 IAC 1248.60, 720 ILCS 570/306, 720 ILCS 570/312, 720 ILCS 570/302, 7 IAC 3100,500. 77 1AC 3100.510, 77 IAC 3100:310, and 77 IAC 3100.330. The Department and Respondent have agreed that this Consent Order resolves all allegations against Respondent known by the Department as ofthe effective date of this Consent Order. 1of6At all times material to the matter set forth in this Order, the Department had jurisdiction over the subject matter and the parties herein. Respondent has been advised of the right to a hearing where the Department bears the burden to prove its allegations by clear and convincing evidence, the right to contest the pending charges and present mitigating evidence, and the right to administrative review of any order resulting froma hearing. Respondent knowingly waives each ofthese rights, as well as any right to administrative review of this Consent Order. Such waiver ceases if this Consent Order is rejected by the Director. Respondent acknowledges that Respondent has entered into this Consent Order freely and of Respondent's own will without threat or coercion by the Department or any person, and has not relied upon any representation made by or on behalf of the Department other than those specifically included herein. Respondent acknowledges that the Department attomey may be requested to communicate with the Director in furtherance of the approval of this Consent Order. Respondent acknowledges this Consent Order will be presented to the Director. If this Consent Order is not approved, Respondent waives any right to raise any prejudice resulting from the Director's consideration of this Consent Order. Respondent understands that this Consent Order is not effective unless and until itis adopted by the Director. A copy of any original signature(s) affixed to this Consent Order shall be given the full force and effect of an original signature(s) affixed to this Consent Order. Respondent and the Department agree in order to resolve case that Respondent be permitted to enter into a Consent Onder with the Department, providing for the terms and conditions contained herein which are fair and equitable in the circumstances and which are consistent with the best interests of the people of the State of Hinois. CONDITIONS ‘Wherefore, the Department, by Department attomey Vaughn G. Bentley, and Respondent, by its attorney Priyanka Desai of Goldberg Law Group, LLC, agree: ‘A. Respondent's Illinois cert ceuthanasia agency license no. 228,000029 shall be placed on indet probation for a minimum of five (5) years. B. Respondent's Illinois certified euthanasia agency license no. 228.000030 shall be placed on indefinite probation for a minimum of five (5) years. 20f6C. During the term of this indefinite probation, Respondent agrees to abide by the following: ‘a. Respondent shall submit quarterly reports containing the following [Name and license number ofeach euthanasia technician employed andior contracted with Respondent; Name and license number of each veterinarian employed and/or contracted with Respondent; ‘Name and license number of any other licensed individuals employed andior contracted with Respondent: ‘The number of unlicensed individuals employed and/or contracted with Respondent; ‘The number of animals euthanized at each of Respondent's facilities; The names, dosage, and amount of each controlled substance ordered for Respondent's facilities; ‘The names, dosage, and amount of each controlled substance used at Respondent's facilities; and ‘Any instances and/or allegations of malpractice or substandard care at Respondent's facilities made by any entity, including and not limited to, any local, state, or federal government agencies. ». Respondent shall send any and all quarterly reports tothe Department no later than January 10h, April 10th, July 10th and October 10th of every year during which Respondent's licenses are on indefinite probation. ¢. Respondent shall submit to unannounced inspections by Department investigators. 4d. Respondent shall maintain controlled substance license no. 329§NNIMP8 and controlled substance fiers no. SIS and sal only use those conte substance Heese ms. oon and track controlled substances for use atthe facility €. Respondent shall not apply for additional certified euthanasia agency licenses without prior written, approval from the Department. 30f6