May 15 2008 13:34 MAY-15-2888 14:69 AHA P.@3 STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, v. CASE NO. 2007-09133 LINDA KAY KING-BLAKE, R.N., RESPONDENT. / AD TIVE COMPLAINT COMES NOW, Petitioner, Department of Health (Department), by and through ‘its undersigned counsel, and files this Administrative Complaint before the Board of Nursing against Respondent, Linda Kay King-Blake, R.N., and in support thereof alleges: 1. Petitioner is the state department charged with regulating the practice of nursing pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter 464, Florida Statutes. 2. At all times material to this Administrative Complaint, Respondent was a registered nurse (R.N.) within the state of Florida, having been issued license number RN 2594922, 3 afb fe— May 15 2008 13:34 MAY-15-2888 14:89 AHCA 3. Respondent’s address of record is 3314 South Main Street, Rockford, Illinois 61102. 4. Rule 64B89-5.002, Florida Administrative Code, requires that each licensed nurse shall, upon request, submit proof satisfactory to the Board of participation in appropriate continuing education. During each biennium, one contact hour must be earned for each calendar month of the licensure cycle. 5. Rule 64B9-5.011, Florida Adminsitrative Code, requires that all licensees must complete a two hour course on prevention of medical errors, which meets the criteria of Section 456.013, Florida Statutes, as part of the total hours of continuing education required for initial licensure and biennial renewal. | 6. Respondent failed to provide proof of compliance with the continuing education requirements for the licensing renewal period ending on or about July 31, 2006. 7. Respondent failed to provide proof of having completed twenty- two (22) hours of general continuing education credit hours for the licensing renewal period ending on or about July 31, 2006. Department of Health v. tinds King-Blake, R.N. 2 Case Number 2007-0913: i: APSU\Nureing Walt\ACSARNAC. RN_CE_KingBlakeL.doc May 15 2008 13:35 MAY-15-2888 14:89 AHCA P.@S 8. Respondent failed to provide proof of having two (2) continuing education credit hours in Prevention of Medical Errors for the licensing renewal period ending on or about July 31, 2006. 9. Section 464.018(1)(0), Florida Statutes (2006), provides that violating any provision of chapter 464, chapter 456, or any rules adopted . Pursuant thereto constitutes grounds for disciplinary action by the Board of Nursing. 10. Respondent violated Section 464.018(1)(0), Florida Statutes (2006), in one or more of the following ways: a. _ By violating Rule 64B9-5.002, Florida Administrative Code, by failing to provide proof of compliance with the continuing education requirements for the licensing renewal period ending on or about July 31, 2006; b. By violating Rule 64B9-5.011, Florida Adminsitrative Code, by failing to provide proof of having two (2) continuing education credit hours in Prevention of Medical Errors for the licensing renewal period ending on or about July 31, 2006; Department of Heatth v. Unda King-Blake, R.N, 3 Case Number 2007-09133 J:\PSU\Nursing\Walt\AC's\RN\AC_RN_CE_KingflakeL.cloc May 15 2008 13:35 MAY-15-2888 14:89 AHCA P.@6 11, Based on the foregoing, Respondent has violated Section 464.018(1)(0), Florida Statutes (2006), by violating any provision of chapter 464, chapter 456, or any rules adopted pursuant thereto. WHEREFORE, the Petitioner respectfully requests that the Board of Nursing enter an order imposing one or more of the following penalties: permanent revocation or suspension of Respondent's license, restriction of practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, corrective action, refund of fees billed or collected, remedial education and/or any other relief that the Board deems appropriate. SIGNED this NS A day of Edvtves “ ; 200 ©. Ana M. Viamonte Rose, M.D., M.P.H. Stata Surgeon General DEPARTM OF HEALTH . ON: Walter T. S. Widener ome Les A, ihacot/ Assistant General Counsel DOH Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, Florida 32399-3265 Florida Bar Number 0037258 - (850) 245 - 4640 Telephone (850) 245 - 4683 Facsimile . 21-08 . vcr BOS open gar + EMULATE Department of Health v. Linda King-Blake, RN. 4 Case Number 2007-09133 J:\PSU\Nursing\Walt\AC's\RN\AC_RN_CE_KingBlakeL doc May 15 2008 13:35 MAY-15-2888 14:18 AHCA Pa? Department of Health v. Linda King-Blake, R.N. Case Number 2007-09133 NOTICE OF RIGHTS Respondent has the right to request a hearing to be conducted in accordance with Section 120.569 and 120.57, Florida Statutes, to be represented by counsel or other qualified representative, to present evidence and argument, to call and cross-examine witnesses and to have subpoena and subpoena duces tecum issued on his or her behalf if a hearing is requested. NOTICE REGARDING ASSESSMENT OF COSTS Respondent is placed on notice that Petitioner has incurred costs related to the investigation and prosecution of this matter. Pursuant to Section 456.072(4), Florida Statutes, the Board shall assess costs related to the investigation and prosecution of a disciplinary matter, which may include attorney hours and costs, on the Respondent in addition to any other discipline imposed. Department of Health v. Linda King-Blake, R.N. : 5 Case Number 7007-09133 J:\PSU\Nursing\Walt\AC's\RN\AC_RN_CE_KingBlakeL.doc

Docket for Case No: 08-002385PL