U oo U) FHLED STATE OF FLORIDA - DEPARTMENT OF HEALTBO JAN \ & PH 3 33 DEPARTMENT OF HEALTH DIVisicis Je a ADMINISTRA JE Petitioner, HEARINGS OO O25 vs. Case No. 99-00403 DEBRA ANN THOMAS, 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, DEBRA ANN THOMAS, and in support thereof alleges: 1. Petitioner is the state agency charged with regulating the practice of nursing pursuant to Chapters 20, 455, and 464, Florida Statutes. 2. Pursuant to the authority of Section 20.43(3)(g), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration to provide consumer complaint, investigative and prosecutorial services required by the Division of Medical Quality Assurance, councils or boards, as appropriate, including the issuance of _emergency orders of suspension or restriction. | 3. Respondent is and has been at all times material hereto, a licensed - PRACTICAL NURSE in the State of Florida, having been issued license number PN 1232481. 4. Respondent's last known address is 811 SW Monica Street, Port St. Lucie, FL 34953. U VU 5. Respondent was entered a plea of guilty and was adjudicated guilty-of Driving Under the Influence. 6. _- Respondent was sentenced to probation but was subsequently sentenced to jail after having been found to have violated her probation. 7. The crime for which the Respondent was convicted directly relates to the practice of nursing or to the ability to practice nursing. 8. Based on the foregoing, Respondent is subject to discipline pursuant to section 464,018(1)(c), Florida Statutes, by being convicted or found guilty of, or entering a plea of nolo contendere to, regardless of adjudication, a crime in any jurisdiction which directly relates to the practice of nursing or to the ability to practice nursing. WHEREFORE, Petitioner respectfully request that the Board of Nursing enter an Order imposing one or more of the following penalties: Revocation or suspension of Respondent's license, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, costs, and/or any other relief that the Board deems appropriate. Signed this 4-day of WO. ; 195 Robert G. Brooks, M.D. Secretary, Department of Health BY: Nancy won Chief Attorney On Behalf of the Agency for Health Care Administration FILED DEPARTMENT OF HEALTH EPUTY CLERK oxen gf tiphamer % » pate So Se OT COUNSEL FO. PETITIONER: Reginald D. Dixoa, Senior Attomey FBN: 0112925 Agency for Health Cate Administration Allied Health Section Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 RDD/td PCP: payrm S:\Nursing\ACs\ac99-00403.doc pom: “\>3)49

Docket for Case No: 00-000259