pai oa ie STATE OF FLORIDA re oe DEPARTMENT OF HEALTH 00 JAN 20 PM 3:40 DEPARTMENT OF HEALTH OLY; insu: ‘ ip Ae ADMINIS antive Petitioner, HEARINGS vs. : Case No. 99-03620 PAULINE CAMPBELL, Respondent. / QO- OB 6 & 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, PAULINE CAMPBELL, 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 1190721. 4, Respondent's last known address is 9505 NW 33rd Place, Sunrise, Florida 33354 and/or 9165 NW 44th Court, Sunrise, Florida 33351. U oo U 14. Respondent's documentation was inaccurate. 15. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, unprofessional conduct by violating Rule 64B9- 8.005(1), F.A.C., by inaccurate recording of patient records. WHEREFORE, Petitioner respectfully request tat 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 wri Alr cay of Nawaniae 19 Robert G. Brooks, M.D. Secretary, Department of Health Nancy Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL FOR THE PETITIONER: Reginald D. Dixon, Senior Attorney FBN: 0112925 Agency for Health Care Administration Practitioner Regulation Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8437 RDDitd PCP: LBVK™M% Dom: /Yaa/¢ 7 S:\Nursing\ACs\ac99-03620.doc

Docket for Case No: 00-000368