STATE OF FLORIDA ; DEPARTMENT OF HEALTH <= DEPARTMENT OF HEALTH Petitioner, 7 mo po vs. Case No. 1999-03734 NORA MARIA AGUILERA, O0-50A1PC 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, NORA MARIA AGUILERA, 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 compiaint, 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 licansed REGISTERED NURSE in the State of Florida, having been issued license number RN 2563072. “gooz 9} Ar 4. Respondent's last known address 1381 SW 22nd Terrace, Miami, Florida 33145-3938, . ~ §— Onor 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 ordared 0.4 mg. 6. On or about March 12, 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. 10. 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 Lt. Wey ot Nb , 2007). Robert G. Brooks, M.D. Secretary, Department of Health BY: ~ Nancy Snurkowski, Chief Attorney On Behalf of the Agency for Heaith Care Administration COUNSEL FQR THE PETITIONER: FILED |. Reginald D. Dixon, Senior Attomey DEPARTMENT rene FBN: 011292 tio Ler Agency for Health Care Administration CLERK aehi R- Allied Health Section : _-(P-JneQ— Post Office Box 14229 DATE, Tallahassee, Florida 32317-4229 (850) 414 - 8437 ROD/rd pep; Wiév 4 pom: ~/# 7/0 COUNSEL FOR THE RESPONDENT: Sean M. Ellsworth, Esquire Dresnick & Ellsworth, P.A. Suntrust Plaza, suite 701 201 Alhambra Circle © Corai Gabies, Florida 33104-5108

Docket for Case No: 00-005029PL