cot ae PY Hd hey tsa Taw STATE OF FLORIDA DEPARTMENT OF HEALTH 00 DEC -5 PH 323 ~ DEPARTMENT OF HEALTH BVie ADMINIS TRAD VE Petitioner, HEARINGS vs. Case No. 1999-62924 MARCELENE ABDULLAH, 00-495; OC 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, MARCELENE ABDULLAH, and in support thereof alleges: 1. Petitioner is the state agency charged with regulating the practice of nursing pursuant to Chapters 20, 456, 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 PRACTICAL NURSE in the State of Florida, having been issued license number PN 1060761. a, cam 4. Respondent's last known address 845 S4th Avenue South, St. Petersburg, Florida 33705. 5. On or about August 16, 1999, while working at The Abbey Nursing Home in St. Petersburg, Florida, Respondent practiced below the minimal acceptable standards of prevailing nursing practice, to wit: Respondent administered insulin to Patient V.D., a "Do Not Resuscitate (DNR)", that was found unresponsive, with no palpable pulse or respiration, in violation of the DNR directive. 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. 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 this Bh day of __( Lipo , 2006. Robert G. Brooks, M.D. Secretary, Department of Health - BY:* Nancy Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL F Reginaid D. D FBN: 0112925 Agency for Health Care Administration Allied Health Section Post Office Box 14229 - Tallahassee, Florida 32317-4229 (850) 414-8576 ,, ,, : RDD/rd pcp:f2**£ pow: ch coe DEPARTMENT OF DEPUTY CLERK 7 CLERK Yahi R. Keron DATE. [4] 2.202

Docket for Case No: 00-004851PL