ore Avail lle te Rana et ede eB Ml le kl el a all Ala a lca ok * STATEOF FLORIDA § LED DEPARTMENT OF HEALTH’ '!= OO JUL 13 PH 3:45 DEPARTMENT OF HEALTH, -DIVISION OF | AD HEISTRATIVE PETITIONER, HEARINGS vs. : . "CASE NUMBER: 99-03349 / BARBARA GONZALEZ 60° If RESPONDENT. mene / ADMINISTRATIVE COMPLAINT COMES Now, the Petitioner, Department of Health, hereinafter referred to as “Petitioner,” and files this Administrative Complaint before the Board of Nursing against BARBARA GONZALEZ, hereinafter referred to as “Respondent,” and alleges: 1. Effective J uly 1, 1997, Petitioner i 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)(g), 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 oe Respondent s last st known address = #21 Onnd ce Canal Drive, Miami, FL 33174-2358. et bole da, co eel alee be ie aa se a 3. On or about:March'23, 1999, in the United States District Court, Southern District of Florida, Respondent was found guilty for Conspiracy to Submit False Claims to the United States. 4. The aforementioned crime directly relates to the practice of nursing or the ability to practice nursing. | 5. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(c), Florida Statutes, by being convicted or found guilty, or entering a plea of nolo contendere to, regardless of adjudication, a crime in any jurisdiction that directly relates to the’ practice of nursing or the ability to practice nursing. 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’ $ 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. SIGNED nix Bley day of f J ny > 2000. Dr. Robert G. Brooks, M.D., Secretary - Department of Health Nancy M. Snurkowski FILED Chief Attorney ae OF HEALTH Agency for Health Care Administration . : Fawr Cea (im O/ Fawr DATE Las ney woke ek Rat a ates Nad COUNSEL FO ONER: Chris Steinhaug ttorney Florida Bar 0147966 Agency for e Administration Allied Heal P.O. Box 14229 Tallahassee, FL 32317-4229 (850) 414-8576 CIS/ejs PCP: LAA VA Ge DATE: oh 7/0 0} ST gr ope rp ee ie ge oe ee NR ra nf oo Far ere oroe eee peer eee soe me ee re

Docket for Case No: 00-002886PL