OO EE EEE | ay STATE OF FLORIDA OQ, O's DEPARTMENT OF HEALTH | , Inds DEPARTMENT OF HEALTH Les. “6 4 oO CM, _ Petitioner, , “tafe en "2 vs. Case No. 2000-04801 STEPHEN W. SIBLEY, ol 0) 281PC, 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, STEPHEN W. SIBLEY, and in support thereof alleges: 7 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 776972. 4. Respondent's last known address is 1815 North Oleander Avenue, Daytona Beach, Florida 32118-3418. 5. On or about February 28, 2000, Respondent was convicted, found guilty or entered a plea of nolo contendere to, regardless of adjudication, a crime which directly relates to the practice of nursing or the ability to practice nursing, to wit: a. One (1) count of Attempted Lewd and Lascivious Assault Upon a Child, a_ third degree felony, in ‘case number 00-30311 CFAES. | b. Two (2) counts of Lewd and Lascivious Assault Upon a Child, a second degree felony, in case number 99-34153 CFAES. 6. 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 third day of OCS pene 200.2 | Robert G. Brooks, M.D. Secretary, Department of Health = -, On Behalf of the Agency for Health Care Administration COUNSEL FOR THE PETITIONER: Reginald D. Dixon, Senior Attorney DEPARTMENT OF HEALTH 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: (ca AA DEPUTY CLERK "RK Mahi R Kenan NATE lofs[ 200 pom: 7 /4]eo od Nancy Snurkowski, Chief Attorney “@,

Docket for Case No: 01-000787PL