oe TST gy LED 00WUL 18 Hig: 33 DEPARTMENT OF HEALTH, A mM ge PETITIONER, NEARINGS vs, CASE NUMBER: 99-62046 DAVID PETERSON OO-AT3 b | 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 DAVID PETERSON, 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, Florida Statutes; and Chapter 464, Florida Statutes. Pursuant to the authority of Section 20.43 (3)(g), 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 Assurance, councils, or boards, as appropriate. 2. Respondent is, and has been at all times material hereto, a licensed REGISTERED Nurse in the'state of F lorida, having been issued license number RN 2629912. Respondent’s last known address is P.O. Box 770223, Coral Springs, FL 33077. VY YW 3. On or about November 3, 1997, in the Circuit/County Court, in and for Broward County, Respondent entered a plea of nolo contendere to one count of Aggravated Assault with a Firearm. 4. The aforementioned crime directly relates to the practice of nursing or the ability to practice nursing. 5. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(c), Florida Statutes, by being convicted or found guilty, or entering a plea of nolo * contendere to, regardless of adjudication, a crime in any jurisdiction that directly relates to the practice of nursing or the ability to practice nursing. WHEREFORE, Petitioner respectfully requests 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, issuance of | a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. SIGNED this 21S} day of (dn , 2000. Dr. Robert G. Brooks, M.D., Secretary - Department of Health FILED DEPARTMENT OF HEALTH DEPUTY K Nancy M. Snurkowski asntrorcce Chief Attomey paTe__G-S-OQ_ Agency for Health Care Administration COUNSEL FOR PETITI Chris Steinhaus, Staff Florida Bar Number 66 Agency for Health Caré Administration Allied Health P.O. Box 14229 Tallahassee, FL 32317-4229 (850) 414-8576 CIS/cjs PcP: AAA~ ME pate: ofa 7faood

Docket for Case No: 00-002936PL