STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH AEA Petitioner, : vs. : Case No. 2000-04636 ANEJ ASL AMIRZADEH, © |- 6 OK % 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, ANEJ ASL AMIRZADEH, and in support thereof alleges: 1. Petitioner is the state agency charged with regulating the practice of nursing pursuant to Chapters 20, 456, 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 3085872. 4. Respondent's last known address is 3602 N. Meridian Road, Tallahassee, Florida 32312. 5. . On or between February 27-28, 2000, while employed by Tallahassee Memorial Hospital, Respondent practiced below the minimal acceptable standards of prevailing nursing practice, by inaccurately recording, altering or falsifying patient records, to wit: Respondent incorrectly recorded/documented a physician's order for Morphine to be administered to patient D.R. via IV infusion pump as 2 mg every 6 minutes with a 4 hours with a lock-out at 30 cc's, when in fact the physician's order was 2 mg every 6 minutes with a 4 hour lock-out at 30 mg, not 30 ce'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 Ly of I ) eo) or 2000, Robert G. Brooks, M.D. Secretary, Department of Health ancy Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL FOR THE PETITIONER: Reginald D. Senior Attorney DEPARTMENT FBN: 01129 DEPUTY CLEREALTH Agency for Health Care Administration CLERK Yh; Allied Health Section Ubi Re Leaeon Post Office Box 14229 vaATE__ 1// 2//o2 Tallahassee, Florida 32317-4229 (850) 414 - 8576 RDD/rd PCP: C¢s #4 DOM: aff3 ‘4.000

Docket for Case No: 01-000657PL