YW STATE OF FLORIDA _ DEPARTMENT OF HEALTH ; | DEPARTMENT ‘OF HEALTH Petitioner, vs. oe _ Case No. 96-17518 ROBIN A. SENIOW GOUVEIA, 60 Sf) OS 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, ROBIN A. SENIOW GOUVEIA, and i in support thereof alleges: 1. “Petitioner | is “the state ageticy 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 j issuance of emergency orders of suspension or restriction. 3. Respondent is and has been at all times material hereto, a licensed REGISTERED NURSE i in the State of Florida, having been issued license number RN 4 1853652, 4, ~ “Respondents ast ‘known “addres is 16356 East Trafalgar Drive, Loxahatchee, Florida 33470. ee ‘Respondent 1 nn ©) 5. On or about July 30, 1996, Respondent was employed by FACILITY and assigned to provided nursing care, including appropriate monitoring and intervention, to patient UT. . 6. On or about July 30, 1996, Respondent assisted patient JT. to the bedside commode so that he could evacuate his bowels. 7. On or about July 30, 1996, Respondent left patient J.T. on the beside commode and exited the room, leaving patient J.T. in the room with no medical Personnel o: or assistance. 8. On or about July 30, 1996, patient J.T. fell while trying to get off the bedside commode and return to his bed. 10. Patient J.T.'s medical condition was such, that the Respondent knew or should have known that the patient was at risk for a fall when left unattended on the bedside commode. 11. Respondent was negligent in leaving patient J.T. on the bedside commode without medical personnel or assistance. 12, Based on the foregoing, Respondent i is s subject to discipline pursuant to section 464,018(1)(h), Florida Statutes, by unprofessional conduct by failing to conform to the minimal acceptable standards of prevailing nursing practice. e oard of Nursing enter an “Order i imposing, one or more © of the following penalties: Revocation or suspension of s license, ‘imposition of an administrative fine, issuance of a reprimand, : placement of the Resr pondent on n probation, ¢ costs, and/or any other relief that the Board deems appropriate. ae Y Signed t thi rday Zthew ot Mos usr , 200. Robert G. Brooks, M.D. Secretary, Departifent of Heal Nancy Snurkowski, On Behalf of the Agency for Health Care Administration COUNSEL OR THE PETITIONER: ixon, Senior Attorney - “Agency for Health Care Administration Allied Health Section Post Office Box 14229 : ; Fr i LED Tallahassee, Florida 32317-4229 DEPARTMENT OF HEALTH (850) 414 - 8576 DEPUTY CLERK COUNSEL FOR THE RESPONDENT: | CLERK Rerwa A o Jay Cohen, Esquire DATE ) ) Klein, Tanned & Cohen, P.A. Presidential Circle 4000 Hollywood Blvd., Suite 620 North Hollywood, Florida 33201 RDD/rd PCP: Boyd & Malasanos DOM: January 28, 2000 hief Attorney

Docket for Case No: 00-001195