STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH Petitioner, vs. Case No. 2000-10740 MARY JEAN GILBERT, Ol- MFO PL 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, MARY JEAN GILBERT, 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 2928852. 4. Respondent's last known address is 440 Lytton Cirle On 1} Florida 32824. , 5. On or about May 15, 2000, Respondent engagey Sie to engage in the possession, sale or distribution of controlled substances under chapter 893, for other than legitimate purposes authorized by 464, to wit: Lortab 6. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(i), Florida Statutes, by engaging or attempting to engage in the possession, sale or distribution of controlled substances under chapter 893, for other than legitimate purposes. 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 (MfAdy ot Mune ,200L, Robert G. Brooks, M.D. Secretary, Department of Health ; BY: {_ Snurkowski, = Attorney FILEBon On Behalf of the Agency for cere Ofek Health Care Administration CLERK o) TE uls ox eae teaneeaR COUNSEL THE PETITIONER: Reginald D. Dixon, Senior Attorney FBN: 0114925 Agency for He {th care Administration Allied Heath Se Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 RDD/rd PCP: ¥¥ BT DOM; 2 fifo!

Docket for Case No: 01-002985PL