Py STATE OF FLORIDA i if & - DEPARTMENT OF HEALTH F te DEPARTMENT OF HEALTH On, . Abn, ‘Petitioner, C3 AS, Re ‘ thine! vs. Case No. 2000-03687 GS WINSTON LLOYD DAVIS, Respondent. / ee ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, DEPARTMENT OF HEALTH, by and through its undersigned counse! and files this administrative complaint before the Board of Nursing against the Respondent, WINSTON LLOYD DAVIS, 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 REGISTERED NURSE in the State of Florida, having been issued license number RN 1831912. Me Ol 12308 © 4, Respondent's last known address is 8720 S.W. 57th Place, Cooper City, Florida 33328. 5. On or about January 26, 2000, while employed by Memorial Regional Hospital, Respondent practiced below the minimal acceptable standards of prevailing nursing practice, to wit: Respondent failed to positively identify patient S.S. resulting in patient S.S. undergoing a cerebral angiogram procedure. 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 | Wh day of wtyuloe , 2000. ‘Robert G. Brooks, M.D. : FILED Secretary, Department of Health OEPARTMENT OF HEALTH DEPUTY CLERK af 4 CLERK inp R- Mba. a ‘a fj ™ pate_( 2/5/52 BY: Nancy Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration {} THE PETITIONER: COUNSEL Reginald D. Allied Health Section Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 : RDDird PCP: 716% “DOM: */7/¢

Docket for Case No: 01-001280PL