fm UU | VU! FILED STATE OF FLORIDA DEPARTMENT OF HEALTH 00 SEP [2 AM IO: 4&4 DEPARTMENT OF HEALTH AGRI: : i Ky iv c Petitioner, HEARINGS vs. Case No. 1999-60490 ELISABETH BYRNE MOORE, 06-360 4 i. 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, ELISABETH BYRNE MOORE, 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. 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 3316112. U . UW . aa " -1) 4. Respondent's last known address 1730 Fairway’ Drive, ‘Lexington, oo sep 12 ANIC: DIV isicis 5. On or about October 20, 1998, Respondent Practica DBE ellina Kentucky 40502. acceptable prevailing nursing practice by testing positive for a drug under chapter 893, without having a prescription and legitimate medical reason for using said drug, to wit: Respondent tested positive for Marijuana on pre- employment drug screen submitted to Manatee Memorial, without having a prescription and legitimate medical reason for using said drug(s). 6. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, by unprofessional conduct by failing to conform to the minimal acceptable standards of prevailing nursing practice. 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 probation, costs, and/or any other relief that the Board deems appropriate. Signed this Sky day oi 2000. Robert G. Brooks, M.D. Secretary, Department of Health FILED DEPARTMENT OF HEALTH yen ae ome een Health Care Administration i an U . U' COUNSE R THE PETITIONER: . 00 SEP 12 ANI: 44 Reginald Di Dixon, Senior Attorney FBN: 01 BV sigh GF Agency for'Heatth Care Administration ADMINISTRATIVE Allied Health Section HEARI Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8437 RDD/rd PCP: 4M ¥ mt 6 Dom: Shrxhoe ¢ COUNSLE FOR THE RESPONDENT: Lister Witherspooon, IV, Esquire 721 NW 14th Court Miami, Florida 33125

Docket for Case No: 00-003804PL