v en”) RECEIVED - LEGAL STATE OF FLORIDA DEPARTMENT OF HEALTH SSFEBI7 AMI: 29 DEPARTMENT OF HEALTH, Petitioner, vs. Case No. 98-03221 JEANNIE CONNOLLY, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF HEALTH, hereinafter referred to as “Petitioner,” files this Administrative Complaint before the Board of Nursing against JEANNIE CONNOLLY, 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 (Supp. 1996); Chapter 455, Florida Statutes; and (Chapter 464, F lorida Statutes. 2. Pursuant to the authority of Section 20.43(3)(g), Florida Statutes (Supp. 1996), Petitioner has contracted with the Agency for Health Care Administration to provide consurher - complaint, d prosecut ervices requ by the Division 1 of Medical Quality Assurance, councils, or boards, as appropriate, including the issuance of emergency orders of suspension or restriction. © 3. Respondent is, and has been at all times material hereto, an Advanced Registered Nurse Practitioner, having been issued license number RN 1840842, w) S) 4. Respondent’s last known address is 1104 South Teakwood Drive, Plant City, FL - 33566. 5. At all times material hereto Respondent was employed by South Florida Baptist Hospital located at 301 North Alexander Street, Plant City, FL 33566. 6. On or about September 6, 1997, Patient Cc. B., a 35 week pregnant female, was admitted to the Emergency Room of South Florida Baptist Hospital, 7. On or about September 6, 1997, Respondent was the Certified Nurse Midwife on duty and received a physician’ s order to give Patient C. B. Magnesium Sulfate, 4 gram bolus IV push. 8. On or about September 6, 1997, Registered Nurse K.R incorrectly prepared the Magnesium Sulfate with 15 grams, rather than 4 grams. 9. On or about September 6, 1997, Registered Nurse K-R. informed Respondent that the bolus was 3.5 grams of Magnesium Sulfate. 10. On or about ‘September 6, 1997, Respondent administered the bolus of Magnesium Sulfate prepared by K.R to Patient C.B., which caused C.B. to go into cardiac arrest, 11. Respondent failed to check the bolus of magnesium sulfate prior to administering » it to ‘the patient. 12, “Based on the forgoing, the Respondent’ s Ticense to practice nursing in the State of Florida is subject to discipline pursuant to Section 464.018, Florida Statutes, by violating Rule 64B9-8. 005(iye2), Florida | Administrative Code, for acts of negligence, gross negligence, either by omission or commission. a TRE et SET TT SER TEE grRE rere 7 Yo w) WHEREFORE, Petitioner respectfully requests the Board of Nursing enter an Order- imposing one or more of the following penalties: imposition of an administrative fine not to exceed $1, 000 for each offe Placement of the Respondent on probation, suspension ¢ or revocation of the ne Respondent” s license, and/or any other relief elief that the Board deems appropriate. ee "SIGNED this wth of Sia (us aa , 199). - Robert G Brooks, M.D. Secretary, Department of Health By: Nancy M. Snurkowski Chief Attorney On Behalf of the Agency for ro . Health Care Administration COUNSEL FOR AGENCY: Reginald D,/Dixon Fl LE D . Senior Attokgey DEPARTMENT OF HEAL H Florida Bar iber 0112925 EPUTY CLER Agency for Health Care Administration "CLERK Q. Dw ~~ General Counsel’s Office-MQA DATE Ai 15-9 4 _ Allied Health OO ~. P.O. Box 14229 . Tallahassee, FL 32317-4229 * (850) 414-8576 RDD/cle PCP: cB} LM DOM: la- 1+- 48

Docket for Case No: 00-002003