PURPOSE: This rule describes the form and content 0,‘ the complaints, the number of copies required, how the complaints are served and how they are amended.

1. (1) Content in General.

   1. (A) Ail complaints shall be in writing.

   2. (B) Petitionershallincludeinthecomplaint:

      1. 1. The full name, address and telephone

number of-

1. A. Petitioner;
2. B. Any attorney representing peti.

timer; and

1. C. Each respondent that is not a state

agency;

1. 2. Suitable space in the caption for the

commission to affix a case number; and

1. 3. Facts in numbered oaraeranhs. each of

which shall contain, as ‘far as p&tical, a single set of circumstances.

1. (C) Petitioner or petitioner’s legal counsel shall sign the complaint.

1. (2) Content of Complaints by Certain Peti. tioners.

   1. (A) An agency’s complaint shall set forth-

      Seereflly Of sale

      1. 1. What licenses the licensee holds from

the agency and whether they are in good standing;

1. 2. Any act thelicensee has committed that

is cause for discipline, with sufficient specificity to enable thelicensee to defend against the charge at hearing; and

1. 3. Any provisions of law that render these

acts cause for discipline.

1. (B) An applicant’s complaint shall-

   1. 1. Set forth the facts which show that the

applicant is entitled to he licensed or to be examined for licensure; and

1. 2. Include a copy of the agency’s decision

or order of which the applicant seeks review.

1. (C) A licensee’s or an aggrieved person’s complaint shail-

   1. I. Identify the agency’s decision or order

for which review is sought; and

1. 2. Include a copy of the agency’s decision

or order of which petitioner seeks review.

1. (D) The complaint of a licensee may

contain a motion for stay.

1. (3) Petitioner shall file the original of the complaint at the commission’s office with sufficient copies for all parties.
2. (4) Notice. The commission shall serve notice of and a copy of the complaint on each respondent by delivery or certified mail. If the attorney genera1 is the petitioner, the commission shall serve the agency which issued the license sought to be disciplined and permit the agency to intervene in the action.
3. (5) Petitioner may amend the complaint without the commission’s leave any time hefore respondent serves a responsive pleading, except as provided in section (6) of this rule. After respondent serves a responsive pleading, petitioner shall amend the complaint only with the commission’s leave.
4. (6) When petitioner is an agency which bears the burden of proof and respondent fails to appear for the hearing, petitioner shall not amend its complaint at hearing with additional allegations against the licensee, unless petitioner shows that it served an amended complaint with the additional allegations on respondent at least fourteen (14) days before the hearing.
5. (7) The commission shall construe the pro% sions of this rule liberally if the petitioner has prepared the complaint without legal counsel.

6. (8) The provisions of this rule, except section (4), apply to amended complaints.

   CODE OF STATE AEGlJLATlONS

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   1CSR 15-2 ,

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Auth: section 621.198, RSMo (1994).* Original rule f&d Aug. 5,1991, effective Feb. 6, 1992. Amended: Filed Oct. 31, 1994, effective May 28,1995. Yhigiizal authority 1965, amended 1978.