le is Ww Mad ay tn L STATE OF FLORIDA oe “ko DEPARTMENT OF HEALTH . “YBoy iy g DEPARTMENT OF HEALTH, “ipfinges @ 46s 4 te PETITIONER, 007638 vs. _CASE NUMBER: RN 1999-03661 DOROTHY L. STRAKER, RESPONDENT. / 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 DOROTHY L. STRAKER, 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, F lorida 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 to provide consumer complaint, investigative, and prosecutorial services required by the Division of : Medical Quality Ass councils bi ds, appropriate. 2. Respondent i is, and has been 2 at all times material hereto, a licensed REGISTERED Nurse i in the state of Florida, having been issued license number RN 2506732. “Resp ess is 133 Berkshire Lane, Palm Coast, “Florida 32137. 3. At all times material hereto, Respondent was s employed by Memorial Hospital in _ Bunnell, Florida. ve Raa ii. u- aa”) 4, Respondent’s conduct, which is the subject of this complaint, is documented by. but not necessarily limited to, the following occasions: a. Onone occasion prior to May 17, 1999, a nursing assistant witnessed . Respondent stuffing a washcloth in the mouth of patient R.V. while the patient was restrained. . b. On another occasion prior to May 17, 1999, a nursing assistant witnessed Respondent plugging the nose of patient P.S., shoving his head back in his chair, and stating to him that he should die. 5. Such conduct by Respondent as outlined above is abusive, unprofessional, and falls below the minimal standards of acceptable nursing practice. 6. Based on the foregoing, Respondent is subject to discipline pursuant to Section 464.018(1)(h), Florida Statutes, unprofessional conduct as defined by Rule 64B9-8.005(13), Florida Administrative Code, failure to conform to the minimal standards of acceptable prevailing nursing Practice. | WHEREFORE, Petitioner respectfully Fequests t 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, i issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the B Board deems appropriate. Wo an) 7 SIGNED this | day of Docume , 1999. 7 Dr. Robert G. Brooks, M.D., Secretary - Department of Health Nancy M. Snurkows Chief Attorney Agency for Health Care Administration COUNSEL FOR PETITIONER: R. Lynn Lovejoy, Senior Attorney Florida Bar Number - 455090 Agency for Health Care Administration Allied Health \ P.O. Box 14229 a Tallahassee, FL 32317-4229 (850) 487-9686 RLL PCP: (Y ovAe DATE: a/se/t) . DEPARTMENT OF HEALTH DEPI ITY CLERK CLERK Uechi R.Vien pate_/3/23/79 sey ee-cRTe

Docket for Case No: 00-001638