STATE OF FLORIDA DEPARTMENT OF HEALTH ene co DEPARTMENT OF HEALTH, PETITIONER, vs. CASE NUMBER: 99-04754 THARON KAY GIVEN TODD, LPN O- b 0 ¢ RESPONDENT. O / 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 THARON KAY GIVEN TODD, 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 ; 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 Nurse in the state of Florida, having been issued license number # 1004961. _Respondent’s last known address is P.O. Box 445, Sopchoppy, Florida 32358. ' 3. On or about March 24, 1975, Respondent pled guilty to Driving Under the Influence (DUI). The Court sentenced the Respondent to 3 days in jail and suspended her driver’s license for 30 days. 4. On or about July 1990, Respondent applied for licensure as a Licensed Practical Nurse and failed to disclose the aforementioned DUI conviction. 5. On or about December 10, 1990, the Board of Nursing issued Respondent a LPN license. Count I 6. Petitioner realleges and incorporates by reference the allegations of fact contained in the foregoing paragraphs as if fully stated herein. 7. 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 a crime which directly relates to the practice of nursing or to the ability to practice nursing. Count II 8. Petitioner reallegs and incorporates by reference the allegations of fact contained in the foregoing paragraphs as if fully stated herein. 9. Based on the foregoing, Respondent is subject to discipline pursuant to Section 464.018 (1)(a), Florida Statutes, by procuring a license to practice nursing by knowing misrepresentations or through an error of the department or the board. 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, a6) SIGNED this day of T1999. and/or any other relief that the Board deems appropriate. Robert G. Brooks, M.D. Secretary, Department of Health cy M. Snurkowski, Chief Attorney Agency for Health Care Administration _,, COUNSEL FOR PETITIONER: ball Carolyn Taylor Staff Attorney, FBN 0127884 Practitioner Regulation Agency For Health Care Administration DEPARTMENT OF HEALTH P.O. Box 14229 oh CLERK Tallahassee, FL 32317-4229 CLERK Whi RLY (850) 487-9644 i R-DMiaon CYT pate_//7/O0 pcp: € OV AL DATE: Ap 9/¢ 7

Docket for Case No: 00-000604