STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH Petitioner, vs. 7 Case No. 2000-11504 RENETTA ASHLEY, O l- Mose 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, Renetta Ashley, and in support thereof alleges: 1. Petitioner is the state agency charged with regulating the practice of certified nursing assistants pursuant to Chapters 20, 456, and 464, Florida Statutes. 2. Pursuant to the authority of Section 20.43(3X0), Florida Statutes, _ the Petitioner has contracted with the Agency for Health Care Administration to provide consumer complaint, investigative and prosecutorial services required by s the Division of Medical Quality Assurance, councils o or boards, as appropriate, including the i issuance of. emergency orders of suspension or restriction. 3. Respondent is and has been at all times material hereto, Certified Nursing Assistant in the State of Florida with license number 0797-265773086 4. Respondent's last known address is 2690 Drew Street Apt. 1003, ce eemeee St. Petersburg, FL 33676. 5. On or. about 8/3/00, while employed by Maxim Healthcare, Respondent made a fraudulent representations in or related to the practice of a profession or employed a trick or scheme in or related to the practice of a profession, to wit: Respondent was scheduled to work a Sunshine Village Nursing home; however she failed to show up to work on 8/3/00 and 8/6/00, and then forged two separate time tickets indicating that she did work on said days. Subsequently, the Respondent was paid by Maxim for services not rendered. — 6. Based on the foregoing, Respondent is subject to discipline pursuant to section 456.072(1)(c), Florida Statutes, by _ making deceptive, untrue, or fraudulent representations in or related to the practice of a profession or employing a trick or scheme in or related to the practice of a profession. WHEREFORE, Petitioner respectfully request that the Board of Nursing imposing one or more ot the following penalties: Revocation or suspension of Respondent's license, ‘imposition of an “administrative fin ine, | ; issuance of a ‘Feprimand, placement of the Respondent on probation, costs, and/or any other relief that the Board deems appropriate Signed this Atlaay of Bak ,200L. Robert G. Brooks, M.D. Secretary, Department of Health rete vr mee emer opr lap ninte pe ane oe mane BY: Nancy Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL FOR THE PETITIONER: om LED Elizabeth A. Hathaway, Staff Attorney DEPUTY CLERK Florida Bar # 0413143 ship. Kener Practitioner Regulation CLERK ‘Ychi R Post Office Box 14229 DATE o Tallahassee, Florida 32317-4229 (850) 414 - 8437 ONS haf / :

Docket for Case No: 01-002708PL