STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH Petitioner, vs. Case No. 99-04655 DAGMARA F. CAL DOMINGUEZ ~ | 06750 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, DAGMARA F. CAL DOMINGUEZ, 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. 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 x boards, as appropriate, including the issuance of ‘emergency orders of 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 1798922. Ww. id 4. Respondent's last known address is 8282 SE 10th Street, Miami, Florida 33144., - 5.. Onr about April 16 or 19, 1999, Respondent pled guilty to one (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), F lorida 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 imposing one or more of the following penalties: Revocation or suspension of ; Respondent's license, imposition of an administrative fine, issuance of a Teprimand, ; Placement of the Respondent on n probation, costs, » and/or any other relief that the Board deems appropriate. - FILED ~ DEPARTMENT OF HEALTH _ DEPUTY CLERK “CLERK Uehi Rion BY: Nancy Snurkowski, Chief Attomey On Behalf of the Agency for DATE. A 40/2000 Health Care Administration SO err rege em ee ee W . . . | , _COUNSEL/FOR THE PETITIONER: _ Reginald}. Dixon, Senior Attormey “Florida ar umber: 0112925 Agency for Health Care Administration ~ Practitioner Regulation «Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8437 RDDid = PCP: LBVL“ DoM: A¢hee® ote pent inmeneegemre en beeen peer capes we eee

Docket for Case No: 00-001506