STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, . _ PETITIONER, | 7 Wi CASE NO, 2017-23489 LISA A. GONZALEZ, 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 Respondent, Lisa A. Gonzalez, R.N., and in support thereof alleges: 1. Petitioner is the state agency 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 9182812. 3. Respondent’s address of record is 436 Fir Grove Rd., Ronkonkoma, NY 11779. 4, The New York State Education Department is the licensing authority for nurses in the state of New York. 5. Respondent holds and/or held registered professional nurse license number 485641 in the State of New York. 6. Onor about November 14, 2017, the New York State Education Department issued an Order against Respondent’s New York registered nursing license suspending the license for a period of one year, imposing a fine of five hundred dollars ($500), staying the suspension of Respondent's New York registered professional nurse license and imposing a one-year period of probation on Respondent's license in lieu of the suspension. 7. Section 464.018(1)(b), Florida Statutes (2017), 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. 8. Respondent had 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, when on or about November 14, 2017, the New York State Education Department issued an Order against Respondent's New York registered nursing license suspending he license for a period of one year, imposing a fine of five hundred dollars ($500), staying the suspension of Respondent’s New York registered professional nurse license and imposing a one-year period of probation on Respondent's license in lieu of the suspension. 9. Based on the foregoing, Respondent violated Section 464.018(1)(b), Florida Statutes (2017), 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. 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. [Signature page follows] SIGNED this _26 day of June , 2018. FILED DEPARTMENT OF HEALTH DEPUTY CLERK CLERK. pate SUN 2 6 2078 /PAC PCP: June 26, 2018 Celeste Philip, MD, MPH State Surgeon General and Secretary Philip A. Crawford Assistant General Counsel Florida Bar No. 91378 Florida Department of Health Office of the General Counsel 4052 Bald Cypress Way, Bin #C65 Tallahassee, FL 32399-3265 Telephone: (850) 245-4640 Facsimile: (850) 245-4662 Email: Philip.Crawford@flhealth.gov PCP Members: Trybulski & Baumwald NOTICE OF RIGHTS Respondent has the right to request a hearing to be conducted jin 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. A request or petition for an administrative hearing must be in writing and must be received by the Department within 21 days from the day Respondent received the Administrative Complaint, pursuant to Rule 28-106.111(2), Florida Administrative Code. If Respondent fails to request a hearing within 21 days of receipt of this Administrative Complaint, Respondent waives the right to request a hearing on the facts alleged in this Administrative Complaint pursuant to Rule 28-106.111(4), Florida Administrative Code. Any request for an administrative proceeding to challenge or contest the material facts or charges contained in the Administrative Complaint must conform to Rule 28-106.2015(5), Florida Administrative Code. Mediation under Section 120,573, Florida Statutes, is not available to resolve this Administrative Complaint. 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.

Docket for Case No: 18-004197PL