Jul 6 2010 11:01 JUL-@6-2618 11:53 AHCA P.a4 STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, v. CASE NO. 2010-00182 MARIA LURLINE KHATIB, R.N., RESPONDENT. I 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 Respondent, Maria Lurline Khatib, 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 licensed registered nurse (R.N.) within the state of Florida, having been issued license number RN 2558992. Jul 6 2010 11:02 JUL-@6-2618 11:53 AHCA P.@S 3. Respondent’s address of record is 1564 Phoenix Drive, Beaumont, California 92223. 4. Respondent's current address may be 10162 North West 23" Street, Coral Springs, Florida 33065-4844. 5S. The Board of Registered Nursing, Department of Consumer Affairs, State of California is the licensing authority for registered nurses in the state of California. 6. Respondent’s California nursing license is license number 588749. 7, On or about December 29, 2009, the Board of Registered Nursing, Department of Consumer Affairs, State of California adopted Respondent's Stipulated Surrender of License and Order. 8. Section 464.018(1)(b), Florida Statutes (2009), provides that having a license to practice nursing revoked, suspended, or otherwise acted against, including the denial of licensure, by the licensing authority of another state, territory, or country constitutes grounds for disciplinary action. 9, Respondent had a license to practice nursing revoked, suspended, or otherwise acted against, including the denial of licensure, by Department of Health v. Maria Lurline Khatii, R.N. 2 Case Number 2010-00182 J:A\PSU\Nursing\Jodi-Ann Johnson\Administrative Complaints\Out of State Violations\Knatlb, Marla Lurline (RN, Q03).doc Jul 6 2010 11:02 JUL-6-2618 14:53 AHCA P.@6 the licensing authority of another state, territory, or country, when the Board of Registered Nursing, Department of Consumer Affairs, State of California adopted Respondent's Stipulated Surrender of License and Order. 10. Based on the foregoing, Respondent violated Section 464.018(1)(b), Florida Statutes (2009), by having a license to practice nursing revoked, suspended, or otherwise acted against, including the denial of licensure, by the licensing authority of another state, territory, or country. Department of Health v. Marla Lurline Khatib, R.N. 3 Case Number 2010-00182 3:\PSU\Nursing\odi-Ann Johnson\Administrative Complaints\Out of State Violations\Khatib, Maria Lurline (RN, 00S).doc Jul 6 2010 11:02 JUL-@6-2618 11:54 AHCA Pa? 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_2°" day of May 2000. Ana M. Viamonte Rose, M.D., M.P.H. State Surgeon General, Department of Health FILED DEPARTMENT Sea ae Barn y. Andere CLERK: Cingele one di-Ann V. Johnsan DATE Sle ib Assistant General nsel DOH Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, Florida 32399-3265 Florida Bar Number 0073525 (850) 245 - 4640 Telephone (850) 245 - 4683 Facsimile /3VI Reviewed and approved by: (initials) (date) PCP: C. HORNE & §, BOWEN PCP Members: s.0/10 Department of Health v. Maria Lurline Khatib, RN. 4 Case Number 2010-00182 2:\PSU\Nursing\Jodi-Ann Johnson \Administrative Complaints\Out of State Violattons\Khatib, Maria Luriine (RN, OOS).ctoc Jul 6 2010 11:02 JUL-@6-2618 11:54 AHCA P.@8 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. Maria Lurline Khatib, R.N. ‘ 5 Case Number 2010-00182 J:\PSU\Nursing\Jadl-Ann Johnson\Administrative Complaints\Out of State Violations\Khatib, Maria Lurline (RN, O05).doc

Docket for Case No: 10-004746PL