YW a wd STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH Petitioner, | O 0 45 vs. oe Case No. 99-02750 LISA M. REYES, L.P.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 the Respondent, LISA M. REYES, LPN., 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 Tequired by the Division of Medical Quality Assurance, councils or boards, as appropriate, including the issuance of emergency orders ofs suspension’ or restriction. . co ie Respondent is ‘and has been at all times material hereto, a icensed PRACTICAL NURSE in the State of Florida, having been issued license number PN 096421. . OB | _ 4, Respondent's last known address is 4205 South Pine Island Rd., Davie, Florida 33328 5. On or about January 25, 1999, Respondent engaged or attempted to engage in the possession, sale or distribution of controlled substances under chapter 893, to wit: Lorcet, by using a forgéd and/ot altered prescription, for other than legitimate purposes. | 6. On or about February 2, 1999, Respondent engaged or attempted to engage in the possession, sale or distribution of controlled substances under chapter 893, to wit: Lorcet, by using a forged and/or altered prescription, for other than legitimate purposes. 7. On or about February 9, 1999, Respondent engaged or attempted to engage in the possession, sale or distribution of controlled substances under chapter 893, to wit: Lorcet, by using a forged and/or altered prescription, for other than legitimate purposes. | 8. . ; On or about February 16, 1999, Respondent engaged or attempted to engage in the Possession, sale or distribution of controlled substances under chapter 893, to wit: Lorcet, by using a 1 forged andlor altered prescription, for other than legitimate purposes. . 9, Base section 464.018(1)(i), Florida Statutes, by engaging or attempting to engage in the possession, sale or distribution of controlled substances under chapter 893, for other than "legitimate purposes. © » Petitioner respectfully request that the Board of Nursing enter an i penalties: Revocation Respondent's license, imposition of an administrative fine, issuance of a reprimand, ‘the. foregoing, Respondent i is ‘subject to , discipline pursuant to suspension \ of GO placement of the Respondent on probation, costs, and/or any other relief that the Board deems appropriate. Signed this Uh ay of | Yawn. » 1990S Robert G. Brooks, M.D. Secretary, Department of Health FILED DEPARTMENT OF HEALTH DEPUTY ERT A cuenk (12h & On Behalf of the Agency for DATE_ ; Health Care Administration COUNSEL FOR THE PETITIONER: Reginald D. Dixpg, Senior Attorney FBN: 0112925. : Agency for Health Care Administration. Allied Health Section Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 RDD/rd pcp: /4v 4a) DOM: 4 3/97 S:\Nursing\Administrative Complaints\reyes-lisa.doc PIE NEE ee preemie

Docket for Case No: 00-000745