on) STATE OF FLORIDA DEPARTMENT OF HEALTH | DEPARTMENT OF HEALTH a << Petitioner, — 6 O07 / [ 3h vs. Case No. 99-04657 BEATRIZ A. ALMARALES 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, BEATRIZ A. ALMARALES, and in support thereof alleges: oo 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 required by the Division of Medical Quality Assurance, ‘councils or boards, as appropriate, including the i issuance of emergency orders of s suspension or restriction. 3. 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 2112212, 4, . Respondent's iast known address 9080 SW 168th Street, Miami, Florida 33196. dita Raat, S. On or about April 16 or 19, 1999, Respondent pled guilty to one ne (1) count of "Conspiracy to Defraud the United State Department of Health and Human Services", in violation of 18 U.S.C. section 371. 6. The Respondent was adjudicated guilty and sentenced to probation. 7. . The crime for which the Respondent was convicted directly relates to the practice of nursing or to the ability to practice nursing. 8. 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, or entering a plea of nolo contendere to, regardless of adjudication, a crime in any jurisdiction which directly relates to the practice of nursing or to the ability to practice nursing. - WHEREFORE, Petitioner respectfully request that the Board of Nursing enter an Order i 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 deems appropriate. R rooks, M.D. ; __, Secretary, Department of Health Signed wi SStle day ate, WA¢7) ; crams obert G. BY: Nancy Snurkowski, Chief Attorney ~~ On Behalf of the Agency for Health Care Administration _FILED ~ DEPARTMENT ¢ OF HEALTH | -DEPUTY CLERK CLERK Deora DATE. eter or ws _. Practitioner Regulation Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8437 RDD/td pcp: LAV AAA pom: ‘/af/x0 ¢ ©

Docket for Case No: 00-001138