é STATEOF FLORIDA} H 2D DEPARTMENT OF HEALTH) JAN 14 PH 9:32 DEPARTMENT OF HEALTH DIVIS.OR SF : ADMINISTRATIVE - Petitioner, -_ HEARINGS © vs. : : Case No. 98-00747 . THOMAS H. VAN DUYN, - - Oo ~26¢ ~Respondeag’” i eset ote oe / . ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, DEPARTMENT OF HEALTH, by and through its undersigned counsel and files this administrative complaint before the Board of Nursing against the Respondent, THOMAS H. VAN DUYN, and in support thereof alleges: 1. Petitioner is the state agency charged with regulating the practice of nursing pursuant to Chapters 20, 455, and 464, Florida Statutes. 2. Pursuant to the authority of Section 20.43(3)(g), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration to provide consumer complaint, investigative and prosecutorial services required by the Division of Medical Quality Assurance, councils or boards, as appropriate, including the issuance of emergency orders of suspension of restriction. 3. Respondent is and has been at all times material hereto, a licensed PRACTICAL NURSE in the State of Florida, having been issued license number PN 1131741. 4. Respondent's last known address is 11400 NE 132nd Street #R106, Kirkland, WA 98034. ada it ry ; things todo than change diapers 5. At all times material hereto, Respondent was employed by Charlotte Regional Medical Center and assigned to provide nursing care to Patient L.M. patient's famil 1 Respondent indicated to Patient L. M.' s family that he was “in charge", that oe he “called. the, shots and that he would catheterize Patie he had "better ” 8. | When confronted regarding the allegation of Patient LM! s family, Respondent admitted that the allegations were e true, 9. ‘Based on, n the foregoing, Respondent is subject to discipline pursuant to... oes o section 464.018(1)(h), Florida Statutes, by failing to conform to the minimal acceptable : standards of prevailing nursing practice. a WHEREFORE, Petitioner respectfully request that the Board of Nursing enter an. Order imposing one or more of the following penalties: Revocation or suspension of Respondent's license, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on * roto costs, and/or any other relief that the Board deems appropriate. Signed nid, of f } Hod > 9 Robert G. Brooks, M.D., Secretary Depagment of Health BY* Nancy Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration DEPARTMENT OF HEALTH - EPUTY CLERK |. cen ihe, Oo . DATE it inate so ee ates eee ee ents E PETITIONER: n, Senior Attorney a Agency for Health Care Administration Allied Health Section . Post Office Box 14229 Tallahassee, Florida 323 17-4229 (850) 414 - - 8576. RDD/rd PCP: “Boyd & Malasanos “DOM: jaa ne 2 4, 356 pein ts cat H:\BOARD\ACS\NURSING\ac98-00747.doc

Docket for Case No: 00-000260