/4 STATE OF FLORIDA . Oy, a & tp, ~&) DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH Petitioner, vs. Case No. 2000-08439 ROXANNA M. RAZZANI, Ol—-(693 PL 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, Roxanna M. Razzani, 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, irivestigative 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 1782282. 4. Respondent's last known address is ADDRESS 1619 Thornhill Circle, Oviedo, FL 32765. 5. On or about 7/14/99, while employed by the Advance Cosmetic Surgery, Respondent practiced below the minimal acceptable standards of prevailing nursing practice, to wit: | The Respondent was employed as the intake nurse at Advance Cosmetic Surgery. The Respondent was responsible for doing the initial assessments of patients preparing to have plastic surgery. While assessing patient D.B., the respondent tried to persuade D.B. to go to another Doctor who she stated was better qualified. The Respondent had D.B. call the doctor she referred while in the examining at Advance Cosmetic Surgery. At that point D.B. felt confused and distraught over the situation and decided to leave Advance Cosmetic Surgery. Using the number she got from D.B.’s chart, the Respondent called D.B. on three separate occasions to see if D.B. scheduled an appointment with the doctor she recommended. 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 4 qiay of (fring 200 {. Robert G. Brooks, M.D. Secretary, Department of Health BY: Nancy Snurkowski, Chief On Behalf of the Agency for Health Care Administration iomey COUNSEL FOR THE PETITIONER: , Elizabeth A. Hathaway, Staff Attorney Florida Bar # 0413143 Agency for Health Care Administration Allied Health Section Post Office Box 14229 ~ Tallahassee, Florida 32317-4229 (850) 414 - 8576 RDDird PCP :/g,¢¢ DOM: /43/200/ DEPARTMENT OF Hi DEPUTY CLERK 7H CLERK Yahi R, Cenen DATE ( [2b fo,

Docket for Case No: 01-001093PL