ke ‘e an STATE OF FLORIDA Up ~& 2’ DEPARTMENT OF HEALTH 4.7, ~/ “ ; Oily BF , Nein, "Weg DEPARTMENT OF HEALTH WE the is on "83 Petitioner, OS Mo vs. Case No. 2000-06712 KATHY LOUISE HALL O! ° 3054 AL 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, Kathy L. Hall, 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 | 279030. | 4. Respondent's last known address is: 3753 Winkler Avenue Extension, Apt. 926, Ft. Myers, FL 33916. . 5. On or about 10/11/99, Respondent self-reported to the Florida “a nn IR Re ream ll f a . F fa Board of Nursing her arrest of 12/27/98, and subsequent c6fiviction én 7/99, for g q gi Ey 99 Driving Under the Influence and Fleeing or Buen yen. chargys being Ay ae misdemeanors of the first degree. AEG 6. Based on the foregoing, Respondent is subject to pursuant to section 464.018(1)(c), Florida Statutes, by being convicted or found guilty of, or entering a plea of nolo contendere to, regardless of adjudication, a crime in any jurisdiction which directly relates to the practice of nursing or 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 reprimand, placement of the Respondent on probation, costs, and/or any other relief that the Board deems appropriate. - Signed atlns Newt . 2004, Robert G Brooks, M.D. Secretary, Department of Health F count ten — 7) he BY: Nancy Snurkowski, hief Attorney CLERK Ynhi R, aren On Behalf of the Agency for DATE 24 lo Health Care Administration COUNSEL FOR THE PETITIONER: James A. Bordonaro Agency for Health Care Administration Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 488-0064 eying t{yo fava St

Docket for Case No: 01-003059PL