STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH Petitioner, vs. Case No. 99-61507 MAVERLYN JOHNSON, 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, MAVERLYN JOHNSON, 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)(e), 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 PRACTICAL NURSE in the State of Florida, having been issued license number PN 1026631. 4. Respondent's last known address is 18911 ‘NW 7th Court, North Miami Beach, Florida 33169. 5. On or about February 26, 1999, the Florida Board of Nursing entered an order placing Respondent's license on probation with certain terms and conditions, including but not limited to: a. "She [Respondent] cannot be employed by a nurse registry, temporary nurse employment agency or home health agency.” 6. Respondent failed to comply with the terms and conditions set forth in the order of the board, specifically, Respondent obtained employment with Progressive Home Health Agency, a home health agency. 7. Based on the foregoing, Respondent is subject to discipline pursuarit to section 455.624(1)(q), Florida Statutes, by violating a lawfully entered order of the Board or Department. 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 thid 3H, day of 4! AKQ , 2000. Robert G. Brooks, M.D. Secretary, Department of Heal DEPARTMENT OF HEALTH BY: Nancy Snurkowski, Chief Attorney DEPUTY On Behalf of the Agency for benihorda Health Care Administration RK pate_- G-1Y-OO_ COUNSEL FO E PETITIONER: Reginald D. Di Senior Attorney FBN: 0112925 Agency for Health Cate Administration Allied Health Section Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 _ RDD/rd PCP: Cov MA pom efi 000

Docket for Case No: 00-005066PL