U U RECEIVED - LEGAL STATE OF FLORIDA DEPARTMENT OF HEALTH .99FEB15 PH 3: 29 DEPARTMENT OF HEALTH Petitioner, Q iO) ~7 Whe 0 vs. , Case No. 98-19553 Me ae ae CHARLENE DIANE QUAM x Respondent. / ADMINISTRATIVE COMPLAINT ran oh 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, CHARLENE DIANE QUAM, 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. Respondent is and has been at all times, material hereto, a licensed PRACTICAL NURSE in the State of Florida, having been iisued license number PN 0671061. 3. Respondent's last known address is 7307 Cypress Drive, New Port Richey, Florida 34653-2904. 4. Respondent called in a prescription to an Eckerd's drug store approving a prescription for thirty (30) Lorcet in the name of the Respondent under the authority of Dr. Van Winkle, the Respondent's personal doctor. 5. The pharmacy called Dr. Van Winkle's office to verify the prescription and was advised that no one from the office approved the prescription. U U 6. - The Respondent presented to the pharmacy to fill the prescription and was arrested and charged with "trafficking in Hydrocodone”. 1. Hydrocodone is a controlled substance under chapter 893, Florida Statutes. . 8. Respondent had no legitimate purpose for possessing or attempting to possess Hydrocodone. 9. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(), Florida Statutes, by engaging or attempting to engage in the possession of a controlled substance under chapter 893, Florida Statutes, for other than legitimate purposes. 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 VA deems appropriate. Signed wided aay of Melors on «19 FILED Robert G. Brooks, M.D. DEPARTMENT OF HEALTH Secretary, Department of Health EPUTY CLERK . cmsphoner ew DATE -[O- G ww) BY: Nancy Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration U U COUNSEL FO PETITIONER: Reginald D. Dix¥n, ‘Si aff Attomey _ FBN: 0112925 . Agency for Health Care Administration Allied Healih Section Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414-8576 RDDird PCP: LIZ/LY) DOM: \/22/94 HABOARD\ACS\NURSING\ac98-19553.doc A

Docket for Case No: 00-000780