U U ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as “Petitioner,” and files this Administrative Complaint before thé Board of Nursing against ROBERT REY, hereinafter referred to as “Respondent,” and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of nursing pursuant to Section 20.43, Florida Statutes ; Chapter 455, Florida Statutes; and Chapter 464, Florida Statutes. Pursuant to the authority of Section 20.43 (3)(£), Florida Statutes, the Petitioner has contracted with the Agency of Health Care Administration to provide consumer complaint, investigative, and * prosecutorial services required by the Division of Medical Quality Assurance, councils, or boards, as appropriate. 2. Respondent is, and has been at all times material hereto, a licensed Nurse in the state of Florida, having been issued license number # 1309472. Respondent’s last known address is 723 Gaston Foster Road, Orlando, Florida 32807. cone STATE OF FLORIDA rtlanD poping DEPARTMENT OF HEALTH UO FEB -8 ANN:u2 DEPARTMENT OF HEALTH, Wve PETITIONER, vs. CASE NUMBER: 99-04613 ROBERT REY, RN 00-465 RESPONDENT. U , V 3. On or about May 1995, the Respondent submitted an employment application to Florida Hospital. On the application, the Respondent indicated that he had not been convicted or currently serving probation for any crime. 4. During the Respondent’s employment, it was alleged that the Respondent threatened a co-worker. Employee Relations conducted an investigation into the Respondent’s background and discovered that the Respondent had been convicted of several misdemeanors and felonies. 5. Following the investigation, Florida Hospital terminated the Respondent’s employment. Count J 6. Petitioner realleges and incorporates by reference the allegations of fact contained in the foregoing paragraphs as if fully stated herein. 7. Based on the foregoing, Respondent is subject to discipline pursuant to Section 464.018 (1)(h), Florida Statutes, by violating Section 464.018 (1)(f), Florida Statutes, by making or filing a false report or record which the licensee knows to be false. Wherefore, Petitioner respectfully requests the Board of Nursing enter an order . imposing one or more of the following penalties: revocation or suspension of the Respondent's license, restriction of the Respondent’s practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. oS Oe U SIGNED thisSPmndk day of LP Uwhhe/_, 1999. Robert G. Brooks Secretary, Department of Health Nancy M. Snurkowski, Chief Attorney Agency for Health Care Administration ED DEPARTMENT OF HEALTH DEPUTY CLERK cienk Wehi R-Bliton pare_(8)23/77__ ww COUNSEL FOR PETITIONER: Carolyn Taylor Staff Attorney, FBN 0127884 Practitioner Regulation Agency For Health Care Administration P.O. Box 14229 Tallahassee, FL 32317-4229 (850) 487-9644 CYT PCP: @a¥44—- DATE: “30/77

Docket for Case No: 00-000665