Petitioner: DEPARTMENT OF HEALTH, BOARD OF NURSING
Respondent: ESTELLE DOUGLAS
Judges: LARRY J. SARTIN
Agency: Department of Health
Locations: Orlando, Florida
Filed: Jul. 14, 2000
Status: Closed
Settled and/or Dismissed prior to entry of RO/FO on Friday, September 29, 2000.
Latest Update: Dec. 25, 2024
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STATE OF FLORIDA
DEPARTMENT OF HEALTH COWUL 14 Py 9: 3
DEPARTMENT OF HEALTH ADHAON OF
HEARINGS. ©
Petitioner,
vs. Case No. 1999-61088
ESTELLE DOUGLAS, 00-290/
Respondent.
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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, ESTELLE DOUGLAS, 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 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
2248982
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4. Respondent's last known address 11021 Bailey Lane, Tamarac, Florida
33321.
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5. ~ On or between January 1999 and October 1999, Respondent practiced
below the minimal acceptable standards of prevailing nursing practice by practicing
beyond the scope of her license, educational preparation or nursing experience, to wit:
While working at the Tamarac Rehab & Health Center,
Respondent provided, and or supervised the provision of,
nursing care to psychiatric patients with medical and or
Psychiatric conditions that the Respondent, and or the
nurses under Respondent's supervision, were not qualified
to care for.
6. Based on the foregoing, Respondent is 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.
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7. On or between January 1999 and October 1999, Respondent practiced
below the minimal acceptable standards of prevailing nursing practice by delegating
professional responsibilities to individuals that the Respondent knew, or should have
known, were not qualified by licensure, educational preparation or nursing experience
to perform, to wit:
While working at the Tamarac Rehab & Health Center,
Respondent assigned nurses to provide nursing care to
patients with medical and or psychiatric conditions that the
Respondent knew, or should have known, the nurses were
: Not qualified to perform.
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8. Based on the foregoing, Respondent is 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.
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 reprimand,
placement of the Respondent on Probation, costs, and/or any other relief that the
Board deems appropriate.
Signed thisJSl_ day of _YY\WQ 2000,
Robert G. Brooks, M.D.
Secretary, Department of Health
Nancy Snurkowski, Chie
On Behalf of the Agency’
Health Care Administration
COUNSEL FORTHE PETITIONER: COUNSEL FOR THE RESPONDENT:
Reginald D. Diz6n, Senior Attomey Karen Goldsmith, Esquire
FBN: 011292 Goldsmith & Grout, P.A.
Agency for Hedith Gare Administration 2180 Park Avenue, North #100
Allied Health Section Winter Park, Florida 32790-2011
Post Office Box 14229
Tallahassee, Florida 32317-4229
(850) 414 - 8437
ag eDy
ROD Ira Filed
PCP: AMY ME DEPARTMENT OF HEALTH
Dom: 2/7/a0t° | CLER —o
OAT OO ee
Docket for Case No: 00-002901PL
Issue Date |
Proceedings |
Sep. 29, 2000 |
Order Closing File issued. CASE CLOSED.
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Sep. 27, 2000 |
Motion to Temporarily Relinquish Jurisdiction (filed via facsimile).
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Sep. 14, 2000 |
Request for Reconsideration of Order of September 11, 2000 or in the Alternative Motion for Rescheduling Hearing (filed via facsimile).
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Sep. 11, 2000 |
Order issued. (Respondent`s motion to hold case in abeyance is denied, Petitioner`s motion to accept qualified representative is granted)
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Sep. 07, 2000 |
Petitioners Motion to Accept Qualified Representative (filed via facsimile).
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Sep. 07, 2000 |
Notice of Appearance and Substitution (filed by E. Hathaway via facsimile).
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Sep. 07, 2000 |
Motion to Hold Case in Abeyance (filed by Respondent via facsimile).
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Aug. 30, 2000 |
Notice of Filing Petitioner`s Response to Requests for Production and Interrogatories (filed via facsimile).
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Aug. 23, 2000 |
Notice of Service of Respondent`s First Set of Expert Interrogatories to Petitioner (filed via facsimile).
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Aug. 14, 2000 |
Respondent`s First Request to Produce to Petitioner filed.
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Aug. 11, 2000 |
Amended Response to Initial Order (filed by Petitioner via facsimile).
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Aug. 11, 2000 |
Notice of Appearance and Substitution of Counsel (filed by M. Duclos via facsimile).
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Aug. 10, 2000 |
Order of Pre-hearing Instructions issued.
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Aug. 10, 2000 |
Notice of Hearing issued (hearing set for October 13, 2000; 9:00 a.m.; Orlando, FL).
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Aug. 07, 2000 |
Response to Initial Order (filed by Petitioner via facsimile).
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Jul. 21, 2000 |
Initial Order issued. |
Jul. 14, 2000 |
Petition for Formal Administrative Hearing filed.
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Jul. 14, 2000 |
Administrative Complaint filed.
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Jul. 14, 2000 |
Agency referral filed.
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