Se RS Py STATE OF FLORIDA Og & a DEPARTMENT OF HEALTH ey a 4 2. DEPARTMENT OF HEALTH “Of Soy, F 55 EAST pF Petitioner, APA yp vs. , Case No. 2000-10202 LESLIE C. ALDRICH, alkla JEFFREY CAMPBELL, 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, LESLIE C. ALDRICH, a/k/a JEFFREY CAMPBELL, 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 9164938, crap em ene 4. Respondent's last known address is Post Office Box 677, Boca Raton, Florida 33429. ° 5. Respondent procured and/or renewed a license to practice nursing in the state of Florida by knowing misrepresentations and/or through an error of the clepartment or the board. 6. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(a), Florida Statutes, procuring, attempting to Procure, or renewing a license to practice nursing by bribery, by knowing misrepresentations, or through an error of the department or the board. 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, issuarice of a reprimand, placement of the Respondent on probation, costs, . and/or any other relief that the Board deems appropriate. Signed this G¢Letey of Xuens ,200f_. --- Robert G. Brooks, M.D. ~ Secretary, Department of Health - EPUTY ono CLERK afithi ke BY: Nancy Snurkow&d, Chief Attorney ly Ye On Behalf of the Agency for DATE= - 4 _ Health Care Administration ucts net eeeee teceireeeremeeenener i Ce te ee Ree COUNSEL FOR THE PETITIONER: Reginald D: fXixon, Senior Attorney FBN: 0112 Agency for Healt’ Care Administration Allied Health’Section Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 RDD/rd.- PCP: DOM: MENM Sfhefo/

Docket for Case No: 01-003826PL