STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH : Petitioner, | O13 71p L vs. | Case No. 2000-08171 IVAN ST. CLAIR, | Respondent. | Lf 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, Ivan St. Clair, 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 3109072. 4. Respondent's last known address is 4212 East Cliffton St., Tampa, FL 33610. 5. On or about April February 4, 1997, the Respondent’s license was suspended due to his failure to comply with Intervention Project for Nurses. 6. On or about April 15, 2000, the Respondent sought employment as a Registered Nurse with Tampa Oaks. 6. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(i), Florida Statutes, by using or attempting to use a license which has been suspended or revoked. 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 thig day of MU i Laur} 200]. Robert G. Brooks, M.D. Secretary, Department of Heal BY: Nancy Snurkowski, Chief Attorney On. Behalf of the Agency for Health Care Administration COUNSEL FOR THE PETITIONER: Elizabeth A. Hathaway, Staff Attorney DEPARTMENT OF HEALTH Florida Bar No. 0413143 TY CLERK Agency for Health Care Administration CLERK Yeh. Kenon Allied Health Section Post Office Box 14229 oare_3/RJor Tallahassee, Florida 32317-4229 Kev PL : 2/0 /

Docket for Case No: 01-001372PL