STATE OF FLORIDA DEPARTMENT OF HEALTH

DEPARTMENT OF HEALTH,

Petitioner,

vs. Case No. 2010-03283

KAREN DAVIS, R.N.

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, Karen Davis, 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 St at ut es; Chapter 456, Florida Statutes; and Chapter 464, Florida Statutes.

2. At all times material to this Complaint, Respondent was a registered nurse ("R.N.") within the state of Florida, having been issued license number RN 9277671.

3. Respondents address of record is 6902 W. Hillsborough

   
   

   DOH v. Karen Davis, R.N. 1

   2010-03283

   J:\PSU\Nursing \An ntionette Smith \AC's\ Davis, Karen, RN-out of state discipline.doc

   Filed July 20, 2011 11:12 AM Division of Administrative Hearings

   Ave, #106, Tampa, Florida 33634.

   
   

4. On or about July 24, 2009, the State of Texas Board of Nursing acted against the nursing license of the Respondent by entering an Order suspending the license of the Respondent until she undergoes a psychological evaluation in which the evaluator deems Respondent safe to practice professional nursing.

5. Section 464.018(1)(b), Florida Statutes (2009), provides that having a license to practice nursing revoked, suspended, or otherwise acted against, including denial of licensure, by the licensing authority of another state, constitutes grounds for disciplinary action.

6. On or about July 24, 2009, the state of Texas Board of

   
   

   Nursing suspended the nursing license of the Respondent.

   
   

7. Based on the foregoing, Respondent violated Section 464.0lS(l)(b), Florida Statutes (2009), for having a license to practice nursing revoked, suspended, or otherwise acted against including denial of licensure, by the licensing authority of another state.

DOH v. Karen Davis, R.N. 2

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 \ tpfi/'\ day of fu0fel"Yv\Gr p<._

I

2010.

FILED

DEPARTMENT OFHEALTH

Ana M. Viamonte Ros, M.D., M.P.H. State Surgeon General

lliuJJJ2 1d    C

Anntionette Smith

CLERK:

U,TY:

CLERK '

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Assistant General Counsel

DOH Prosecution Services Unit

DATE C/- /_'/

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4052 Bald Cypress Way, Bin C-65 Tallahassee, Florida 32399-3265 Florida Bar Number 0615951 (850) 245 - 4640 Telephone

(850) 245 - 4683 Facsimile

e.

PCP: Y/Ile/ iD .,

PCP Members: () . t vtG1

\.\t1Y1 10

DOH v. Karen Davis, R.N.

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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.

OOH v. Karen Davis, R.N. 4

Docket for Case No: 11-003496PL