WW. ee STATE OF FLORIDA bn - DEPARTMENT OF HEALTH ‘o Mp DEPARTMENT OF HEALTH, Petitioner, vs. . CASE NO. 98-14536 MARIA RODRIGUEZ, Respondent. ADMINISTRATIVE COMPLAINT COMES NOW the Petitioner, Department of Health, and files this Administrative Complaint before the Board of Clinical Laboratory Personnel, against the Respondent, MARIA RODRIGUEZ, and in support thereof would state: , 1. Petitioner is the state agency charged with regulating the practice of Clinical Laboratory Personnel, pursuant to Section 20.43, Florida Statutes; Chapter 455, Florida Statutes; and Chapter 483, 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, hereinafter referred to as the "Agency," to provide consumer complaint, investigative, and prosecutorial services required by the Division of Medical Quality Assurance, councils or board, as appropriate, including the issuance of emergency orders of suspension or restriction. v, Nd . 3. Respondent has been at all times pertinent hereto, a duly licensed clinical laboratory technologist pursuant to Chapter 483, Florida Statutes, having been issued license number JC 0018631. 4. Respondent's last known address is 12244 Dakota Wood Lane, Orlando, Florida 32824. 5. From January 1995 through May of 1996 the Respondent was the acting baad Hematology Supervisor at Colombia Medical Center, 818 Main Lane, Orlando, Florida, and performed all of the duties and responsibilities of a supervisor. 6. The conduct of the Respondent as aforesaid in contrary to the provisions of Section 483.825 (2), Florida Statutes, by engaging in clinical laboratory categories or procedures, to wit: those of a Clinical Laboratory Supervisor, not authorized by her license as a Clinical Laboratory Technician. WHEREFORE, Petitioner respectfully requests the Board of Clinical Laboratory Personnel to enter an Order imposing one or more of the penalties proscribed by law, together with any other and further relief deemed just under the circumstances. . is/ fAday of L U Oras , 1999. ns - Robert G. Brooks, M.D. E i Le D Secretary, Department of Health ’ DEPARTMENT OF HEALTH EPUTY CLERK CLERK Q, : : y: Nancy M. Snurkowski pare, O09 F Chief Attorney On Behalf of the Agency for _ Health Care Administration COUNSEL FOR AGENCY: Lawrence F. Kranert, Jr. Senior Attorney s . Florida Bar No. 0171063 Agency for Health Care Administration General Counsel's Office - MQA Allied Health P.O. Box 14229 Tallahassee, Florida 32317-4229 (850) 487-2225 KP. (LUA MOGI RE

Docket for Case No: 00-001182