STATE OF FLORIDA oO o DEPARTMENT OF HEALTH Be 2 = ae - DEPARTMENT OF HEALTH z . Petitioner, BP C3 Oo vs. Case No. 4999-03737 Toe = CYNTHIA F. DE GUZMAN PINEDA, 60 -BYLO AL 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, CYNTHIA F. DE GUZMAN PINEDA, 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 1569692. 1, d? 4. Respondent's last. known address 1241 SW 102nd. Avenue, Pembroke Pines, Florida 33025. — 5. On or about March 10, 1999, While working at the Cedars Medical Center, Respondent practiced below the minimal acceptable standards of prevailing ‘nursing practice by administering medications or treatments in a negligent manner, to patients under her care, to wit: Respondent administered 4 mg. of Vincristine to Patient P.V. instead of the physician ordered 0.4 mg. 6. On or about March 11, 1999, While working at the Cedars Medical Center, Respondent practiced below the minimal acceptable standards of prevailing nursing practice by administering medications or treatments in a negligent manner, to patients under her care, to wit: Respondent administered 4 mg. of Vincristine to Patient P.V. instead of the physician ordered 0.4 mg. 7. 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. < ig 4 Signed thid Dheckor Ny li , 208). Robert G. Brooks, M.D. Secretary, Department of Health BY: Nancy Snurkowski, Chief Attorney On Behaif of the Agency for Health Care Administration COUNSEL FOR THE PETITIONER: Reginald D. Dixon, Senior Attoney FBN: 0112925 Agency for Health Care Administration Allied Health Section Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8437 RDO/rd pcp:.Vig ¥ 47 DOM: s/s acer COUNSEL FOR THE RESPONDENT: Sean M. Ellsworth, Esquire Dresnick & Ellsworth, P.A. Suntrust Plaza, suite 701 201 Alhambra Circle Coral Gables, Florida 33104-5108

Docket for Case No: 00-005026PL