STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH Petitioner, vs. Case No. 1999-60581 GUY ROSS, 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, GUY ROSS, 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 3148522. 4. Respondent's last known address is 3091 NW 46th Avenue Apt. 201, Lauderdale Lakes, Florida 33313. 5. On or about April 17, 1995, Respondent was convicted, found guilty or entered a plea of nolo contendere to, a crime which directly relates to the practice of nursing or the ability to practice nursing, to wit: Driving Under the Influence. 6. On or about March 25, 1999, Respondent was convicted, found guilty or entered a plea of nolo contendere to, a crime which directly relates to the practice of nursing or the ability to practice nursing, to wit: Driving Under the Influence. 7. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(c), Florida Statutes, by being convicted or found guilty of, or entering a plea of nolo contendere to, regardless of adjudication, a crime in any jurisdiction which directly relates to the practice of nursing or to the ability to practice nursing. 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 thi Qn day of (WG 2008. _ Robert G. Brooks, M.D. Secretary, Department of Health acid 61 438 00 \ ocpah te al DEPUTY CLERK LTH On Behalf of the Agency for CLERK Uebif g Health Care Administration DATE. D-Y/- Devoe a eeeemnaiinaenanatinee = COUNSEL FOR THE PETITIONER: Reginald D. Dikgn, Senior Attorney Florida Bar Number: 0112925 Agency for Health Care Administration Practitioner Regulation Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8437 RDD/rd PCP: Cov 4A DoM: ¥/« 2a ood

Docket for Case No: 00-003883PL