May 26 2009 14:49 MAY-26-2009 15132 i . Pont STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, v. CASE NO. 2007-18554 \, = TIMOTHY ALLAN GOOSBY, A.R.N.P., oy G RESPONDENT. ead ADMIN VE COMPLAINT COMES NOW, Petitioner, Department of Health, by and through its undersigned counsel, and files this Administrative Complaint before the Board of Nursing against Respondent, Timothy Allan Goosby, A.R.N.P,, 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 licensed advanced registered nurse practitioner within the state of Florida, having been issued license number 3085412. Department of Health v. Timothy Allan Goosby, A.R.N.P. Case Number 2007-18554 7:\PSU\Nursing\Walt\AC's\ARNP\AC_ARNP_OutOfStateDiscipline_« GoosbyA.doc May 26 2009 14:49 MAY-26-2689 15:32 AHCA P.@9/11 3. Respondent’s address of record is PO Box 138, Cameron, Wisconsin 54822. 4. On or about July 15, 2005, the Texas State Board of Nursing entered an order for Respondent to voluntarily surrender his Texas Registered Nursing License. 5. The Texas Board of Nursing is the licensing authority for registered nurses in the State of Texas. 6. Onor about June 12, 2007, the Texas State Board of Nursing reinstated Respondent’s Registered Nursing License by a conditional order. 7, Section 464.018(1)(b), Florida Statutes (2006), provides that having a license to practice nursing suspended, or otherwise acted against by the licensing authority of another state constitutes grounds for disciplinary action. 8. On or about July 15, 2005, the Texas State Board of Nursing acted against the Respondent's nursing license by entering an order for Respondent to voluntarily surrender his Texas Registered Nursing License. | 9. Based upon the foregoing, Respondent has violated Section 464.018(1)(b), Florida Statutes (2006), by having her license to practice nursing acted against by the licensing authority of the State of Texas. Department of Health v. Timothy Allan Goosby, A.R.N.P. Page 2 Case Number 2007-18554 JAPSU\Nursing\WaltlAC's\ARNP\AC, "_ARNP_OutOfStateDiscipline_GoosbyA doc M4 : MAY-26-2689 15:32 AHCA ay 20 2009 eS P1811 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 _\S day of ___Cev(var 2008. Ana M. Viamonte Ros, M.D., M.P.H. State Surgeor\General DEPARTMENT OF HEALTH EPUTY OL lt CLERK: pare__Jligl05 Walter T. 5S. Widener Assistant General Counsel DOH Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, FL 32399-3265 Florida Bar Number 0037258 (850) 245-4640 (850) 245-4683 Fax . 218-08 aie Ke Una Be Department of Health v. Timothy Allan Goosby, ARLN.P. : Page 3 Case Number 2007-18554 JAPSU\Nursing\Walt\AC’s\ARNP\AC_ARNP_OwtOfStateDiscipline_GoosbyA.doc MAY-26-2689 15:32 AHCA May 26 2009 14:50 P.iivit Department of Health v. Timothy Allan Goosby, A.R.N.P. Case Number 2007-18554 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 CcosTS 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. Timothy Allan Goosby, A.RN.P. Page 4+ Case Number 2007-18554 JAPSUANorsing\Walt\AC’s\ARNP\AC_ARNP__Qut0fStateDiscipline..GoosbyA.doc TOTAL FP.ii

Docket for Case No: 09-002871PL