&X STATE OF FLORIDA __.. DEPARTMENT OF HEALOY’:, DEPARTMENT OF HEALTH, PETITIONER, vs. CASE NUMBER: 99-02948 NILO VERDEJO pe RESPONDENT. QO ~O6 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 NILO VERDE)JO, 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 (hereinafter “Agency”) 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 PRACTICAL Nurse in the state of Florida, having been issued license number PN 1245421. Respondent’s last known address is 6531 Brookridge Trail, Lakeland, FL 33810. 3. At all times material hereto, Respondent was employed by Meadowview Life Center (hereinafter “MLC”) and assigned to the 11:00 p.m. to 7:00 a.m. shift. WU Nw] 4. On or about April 5, 1999, the Agency’s Health Quality Assurance division received a complaint that Respondent was leaving the MLC premises for approximately one (1) to two (2) hours during his shift and would return smelling of alcohol. 5. On or about April 7, 1999, the Agency responded to this complaint by conducting an survey of MLC. 6. On or about April 7, 1999, during the survey, Respondent was witnessed in his car consuming and stirring a beverage. 7. On or about April 7, 1999, upon returning from his car, Agency surveyors reported that Respondent’s breath smelled of alcohol. 8. Based on his aforementioned conduct, Respondent has failed to adhere to the... minimal acceptable standards of prevailing nursing practice. . 9. _ Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, by unprofessional conduct, which shall include, but not be limited to, any departure from, or the failure to conform to, the minimal standards of acceptable and prevailing nursing practice, in which case actual injury need not be established. YU Y 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 day of BNNs ae 1999. Dr. Robert G. Brooks, M.D., Secretary - Department of Heal ancy M. Snurkowski Chief Attorney Agency for Health Care Administration COUNSEL FOR PETI : re Chris Steinhaus, S$ ey DEP FILED Florida Bar Numbe: 6 Agency for Health Care Administration Allied Health P.O. Box 14229 . Tallahassee, FL 32317-4229 - 850) 414-8576 CISicis pep: /GVvba) parelao/4#

Docket for Case No: 00-000858