E Ol 4932 py . ’ STATE OF FLORIDA RECEIVED - LEGAL DEPARTMENT OF HEALTH QOMAR 17 PH 3:59 ( ‘ DEPARTMENT OF HEALTH, PETITIONER, vs. CASE NUMBER: RN 1999-02612 KATHERINE J. G. KRAVITZ RESPONDENT. ADMINISTRATIVE COMPLAINT can! COMES NOW, the Petitioner, Department of Health, hereinafter referred to as “Petitioner,” and files this Administrative Complaint before the Board of Nursing against KATHERINE J. G. KRAVITZ, hereinafter referred to as “Respondent,” and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of nursing pursuant to Section 20.43, Florida Statutes; Chapter 455, Florida Statutes; and edit ae eee 2 Chapter 464, Florida Statutes. Pursuant to the authority of Section 20.43 (3)(f), Florida Statutes, the Petitioner has contracted with the Agency of Health Care Administration to provide consumer complaint, investigative, and prosecutorial services required by the Division of Medical Quality Assurance, councils, or boards, as appropriate. 2. Respondent is, and has been at all times material hereto, a licensed REGISTERED Nurse in the State of Florida, having been issued license number 1614572. Respondent’s last known address is 3739 Highway C315, Green Cove Springs, FL 32043. 3. At all times material hereto Respondent was employed by North Florida Reception Center Hospital in Lake Butler, FL 32054. tae hi ha ee ie aoe 4... Onor about March 13, 1999, patient A.J. was transferred back to the North Florida Reception Center Hospital after having undergone a coronary by-pass graft at Memorial Medical Center in Jacksonville, FL. 5. A.J.’s chart did not contain a “Do Not Resuscitate” order. 6. North Florida Reception Center Hospital has a written policy that CPR shall be initiated in all cases of cardiac and/or respiratory arrest except those inmates who have signed a “Do Not Resuscitate” form and that form is present in the chart. 7. Progress records show that there is a written statement that there is not a declaration concerning life prolonging procedures in the chart. 8. On or about March 17, 1999, patient A.J. was found unresponsive in a geriatric chair in the early evening. Patient had no respiration, no pulse and no blood pressure. 9. Respondent came upon the scene and directed the patients care. 10. Respondent hooked up EKG leads and asked another nurse to call the ER doctor. the Respondent made no attempt to resuscitate the patient, 12. Based on the foregoing, Respondent is subject to discipline pursuant to Section 464.018(1)(h), F lorida Statutes, professional conduet as further defined by Rule 64B9-8.005(13) failure to conform to the minimal standards of acceptable prevailing nursing practices, regardless of whether 0 or r not + actual j injury toa 2 patient was sustained. WHEREFORE, Petitioner respectfully requests the Board of Nursing enter an order imposing one or more of the following penalties: revocation or suspension of the Respondent’s license, restriction of the Respondent’s practice, imposition of an administrative fine, issuance of ST er ate worm > See opp omer perenne a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. . . f : SIGNED wil Wh ory of hve y , 2000. COUNSEL FOR PETITIONER: R. Lynn Lovejoy, Senior Attorney Florida Bar Number - 0455090 Agency for Health Care Administration Allied Health ; \Y 2727 Mahan Drive : dV Tallahassee, FL 32308 \ (850) 410-0619 RLL/lad pep: COVAL DATE: “/29/ 300 p) Dr. Robert G. Brooks, M. Secretary - Department of/Health Chief Attorney Agency for Health Care Administration FILED DEPARTMENT OF HEALTH DEPUTY CLERK CLERK Webi RM on pate_3-/ 222002 re Cem pep ere ge

Docket for Case No: 01-004938PL