U ~ a a?) a (yee gear er prorpa ‘RECEIVED! bb bu) DEPARTMENT OF HEALTH 99 FEB 45 flv bed Gris 3 33 DEPARTMENT OF HEALTH ; ik iS Bios Da Sido nt 7 ADMIN “Petitioner, : — _ _ HEARINGS ™~Sase No. 97-08108 mS: IM ANN MARSTON, 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, k ‘KIM ANN MARSTON, and in support thereof alleges: 4. ; “Pett ler is the state ‘agency charged with regulating the practice of nursing pursuant to Chapters 20, 455, and 464, Florida Statutes. + 2. Respondent is “and ‘has been at all times ‘naterial “hereto, a licensed | - REGISTERED NURS! the Siate of Florida, having been issued license number RN 66582 7 and initiate contact with Patients/clients. Order. imposing 0 one or more of the. following penis Revocation or r suspension of 6. The Respordent’ employe ‘subsequently 4 instructed Respondent not to have any contact with their patients/lients - 7. "Despite the instructions from her employer, Respondent continued to call SI ondent made multiple cals to patientstients rising to the level of harassing the clients. 9. The patientsfelients have desoribed “the Respondent’ repeated calls as ~ abusive. “10. Based on the foregoing, Respondent's license to practice nursing is subject to “discipline pursuant to section 464. 018(1)(h), Florida Statutes, for unprofessional ‘conduct by failing to conform to the minimal acceptable standards of nursing practice. _ WHEREFORE, Petitioner respectfully request that th e e Board of Nursing enter an Nancy Snurkowski, Chief Attorney — On Behalf of the Agency for Health Care Administration VY COUNSEL FO PETITIONER: Reginald D. Dixén, Senior Attorney "FBN: 0112925) Agency for Health Care Administration Allied Health Section “Post Office Box 14229 ‘Tallahassee, Florida 32317-4229 ~ (850) 414-8576 ee

Docket for Case No: 00-002067