DEPARTMENT OF HEALTH vig ce ‘ puta be ; ADMINIS RAVIVE. DEPARTMENT OF HEALTH HEARINGS Petitioner, vs. Case No. 97-19211 HELEN MARY BEAUDOIN, QO “A go Respondent. . / 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, HELEN MARY BEAUDOIN, 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 or restriction. . UY WY 3. Respondent is and has been at all times’ material hereto, a licensed REGISTERED NURSE in the State of Florida, having been issued license number RN 3164352. 4. Respondent's last known address is 3499 NE 4" Avenue, Boca Raton, Fl 33431. 5. On or about October 29, 1997, a search was conducted of Respondent’s residence by the Boca Raton Policed Department pursuant to a lawful warrant. 6. During the search the police officers found the following legend medications: a) Nifedipine b) Diltaizem c) Trazdone d) Kefflex e) Fioricet 7. Respondent informed the police officers that she did not have a valid prescription for these medications and that they had been taken without authorization from her then employer Boca Raton Community Hospital. 8. Respondent’s misappropriation of these legend drugs from her employer is unprofessional conduct. 9. ‘Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, for unprofessional as defined by Rule 64B9- 8.005(1)(e)3, Florida Administrative Code, for misappropriating supplies, equipment or drugs. 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, 7 AA . placement of the Respondent on probation, costs, and/or any other relief that the Board deems appropriate. Signed ng AG aay of Mens , 1999, Robert G. Brooks, M.D., Secretary Department of Health Nancy Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL FOR THE PETITIONER: Reginald D. Dixon, Senior Attorney F | LE D AUTH FBN: 0112925 DEPARTMENT OF OK Agency for Health Care Administration EPU . Q Allied Health Section CLERK ' Post Office Box 14229 DATE Tallahassee, Florida 32317-4229 (850) 414 - 8576 RDD/ser PCP: B|Lm pom: 5|>8]44

Docket for Case No: 00-000289