STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, | . v. ~ CASE NO. 2017-09639 WENDI GONZALES, 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, Wendi Gonzales, 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 licensed registered nurse (RN) within the state of Florida, having been issued license number RN 9455641. 3. | Respondent's address of record is 965 Misty Meadows Trail, Twin Falls, Idaho, 83301. 4. The Virgin Islands Board of Nurse Licensure is the licensing authority for nurses in the territory of the United States Virgin Islands. 5. On or about April 6, 2017, Respondent applied for licensure by endorsement for the privilege to practice as a Registered Nurse in the United States Virgin Islands. 6. On or about May 3, 2017, the Virgin Islands Board of Nurse Licensure denied Respondent's application. 7. Section 464.018(1)(b), Florida Statutes (2016), 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 denied by the licensing authority of another territory when on or about May 3, 2017, the Virgin Islands Board of Nurse Licensure denied her endorsement application for the privilege to practice nursing. Department of Health v. Wendi Gonzales, R.N. a 2 Case Number 2017-009639 9. Based on the foregoing, Respondent violated Section 464.018(1)(b), Florida Statutes (2016), 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. ] Department of Health v. Wendi Gonzales, R.N. 3 Case Number 2017-009639 SIGNED this 25th ___ day of October _, 2017. Celeste Philip, MD, MPH State Surgeon General and Secretary [x ApwL. Prescott Ann L. Prescott Assistant General Counsel | Florida Bar No. 0092974 FILED Florida Department of Health DEPARTMENT OF HEALTH ©” Office of the General Counsel Any oe CLERK 4052 Bald Cypress Way, Bin #C65 CLERK: HE 2S 017 Tallahassee, FL 32399-3265 ~~" Telephone: (850) 558-9886 | Facsimile: (850) 245-4662 Email: Ann.Prescott@flhealth.gov /ALP PCP: October 25, 2017 PCP Members: Denker (chair) & Desmond Department of Health v. Wendi Gonzales, R.N. Case Number 2017-009639 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. 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. Department of Health v. Wendi Gonzales, R.N. . . 5 Case Number 2017-009639 : us

Docket for Case No: 19-005906PL