STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, vs. CASE NUMBER: 97-17403 JEWLEEN KWON RESPONDENT. / OO “OD Y/ Vi ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as “Petitioner,” and files this Administrative Complaint before the Board of Nursing against JEWLEEN KWON, hereinafter referred to as “Respondent,” and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of nursing pursuant to Section 20.43, Florida Statutes (Supp. 1996); Chapter 455, Florida Statutes; and Chapter 464, Florida Statutes. Pursuant to the authority of Section 20.43 (3)(f), Florida Statutes, the Petitioner has contracted with the Agency of Health Care Administration to provide consumer complaint, investigative, and prosecutorial services required by the Division of Medical Quality Assurance, councils, or boards, as appropriate. 2. Respondent is, and has been at all times material hereto, a licensed REGISTERED Nurse in the state of Florida, having been issued license number RN 1491322. Respondent’s last known address is PO Box 389, Lynn Haven FL 32444. 3. At all times material hereto, Respondent was employed by Dr. Syed Mahmood. wy) ad 4. During Respondent's employment with Dr. Mahmood, Dr. Mahmood pre-signed prescriptions for patients and allowed Respondent to use her judgement to prescribe medications for patients. 5. Dr. Mahmood and Respondent admitted to the aforementioned practice. 6. On or between October 19, 1994, and August 30, 1997, Respondent used the pre- signed prescriptions to obtain the following prescription medications for her own use: Accutane, Doxapap, Oxycodone, Roxicet, Premarin, Phentermine, Pondimin. 7. At no time material hereto was Respondent a patient of Dr. Mahmood. 8. Pursuant to chapter 893, Florida Statutes, Oxycodone, Roxicet, and Phentermine are controlled substances. 9. Respondent did not have a valid prescription for or a legitimate purpose engaging in the possession of the aforementioned controlled substances. Count I 10. Petitioner realleges and incorporates by reference the foregoing allegations of fact contained in the foregoing paragraphs as if fully stated herein. 11. Based on the foregoing, Respondent is subject to discipline pursuant to Section 464.018(1)(h), Florida Statutes, unprofessional conduct as defined by Rule 64B9-8.005(1)(e)15., Florida Administrative Code, by practicing beyond the scope of the licensee's license, educational preparation, or training. Count 12. Petitioner realleges and incorporates by reference the foregoing allegations of fact contained in the foregoing paragraphs as if fully stated herein, WU UY 13. Based on the foregoing, Respondent is subject to discipline pursuant to Section 464.018(1)(i), Florida Statutes, for engaging or attempting to engage in the possession, sale, or distribution of controlled substances as set forth in Chapter 893, for any other than legitimate purposes authorized by this chapter. WHEREFORE, Petitioner respectfully requests the Board of Nursing enter an order imposing one or more of the following penalties: revocation or suspension of the Respondent’s license, restriction of the Respondent’s practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. SIGNED this | 4) day of YYW th , 1999. Robert G. Brooks, M.D. Secretary, Department of Health Nancy M. Snurkowski Chief Attorney Agency for Health Care Administration COUNSEL FOR PETITIONER: Chris Steinhaus, Attomey €S? FILED Florida Bar Number - 0147966 DEPARTMENT OF HEALTH Agency for Health Care Administration EPUTY CLERK Allied Health CLERK HPiphas 0. uw P.O. Box 14229 Tallahassee, FL 32317-4229 Date. SIG - VQ (850) 414-8576 CIS/cjs | PCP:RY BY | DATE: Ae\09 .

Docket for Case No: 00-000411