STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH Petitioner, vs. ~ Case No. 2000-06727 : PAMELA LINDSEY, ; ; : ag edhatscly boas ou Soe pe Ol- 185d PL Respondent. ees / . 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, Pamela Lindsey, and in “support thereof alleges: 1. Petitioner is the state agency charged with regulating the practice of _ hursing 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 1427722. 4. Respondent's last known address is 1215 E. North Street, Tampa, FL33604 # te 7. The Respondent fraudulently used a stolen credit card, that belong to another nurse, to Purchase items. . 8. ‘The then and fraudulent use of the credit card was investigated by the Tampa Police Department. 9. On or about May 6, 1999, the Respondent pled nolo contendere to grand theft and fraudulent use of a credit card; both pleas are third 5d degree felonies defined d by chapters 812 and 817 respectfully. . 10. Under ‘Section 464, o18(1y@, Florida Statutes, “the Florida State Legislature has defined theft under chapter 812 and fraudulent practices under chapter 817 to be > directly related to practice of nursing. vn 11. Based on the foregoing, Respondent i is subje ect to o discipline pursuant to Section 464.018(1)(c), Florida Statutes, by pleading nolo contendere to, regardless of adjudication, a crime in any jurisdiction which directly relates to the practice of nursing or to the ability to practice nursing. , 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 Teprimand, placement of the Respondent on probation, costs, and/or any other relief that the Board deems appropriate. Signed hislshaay of fag my a) 2p. ! Robert G. Brooks, M.D. FILED Secretary, Department of Health DEPARTMENT OF HEALTH DEPUTY CLERK cuerk Wahi R Keron , i, Chief Attorney _ DATE c ot . oO On Behalf of the Agency for Health Care Administration COUNSEL FOR THE PETITIONER: Elizabeth A. Hathaway, Staff Attorney FBA# 0413143 Agency for Health Care Administration Allied Health Section Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 RDD/rd PCP: a aT DOM: —e5/ of

Docket for Case No: 01-001850PL