ae a STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH Petitioner, vs. Case No. 2000-14315 DAVID PETERSON . Respondent. ee | 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, DAVID PETERSON, and in support thereof alleges: Petitioner is the state agency charged with regulating the practice of nursing pursuant to Chapters 20, 456, and 464, Florida Statutes. Pursuant to the authority of Section 20.43(3)(g), Florida Statutes, 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. Respondent is and has been at all times material hereto, a licensed Registered Nurse in the State of Florida, having been issued license number 2629912. “10. 11. 12. 13. xr t oat, Respondent is and has been at all times material hereto, a Advanced Registered Nurse Practitioner in the State of Florida, having been issued certificate number 51659 and in conjunction thereof by offering nursing services for a fee. Respondent's last known address is P.O. Box 1311, Lake Worth, FL 33460. COUNT I . Respondent has distributed business cards on behalf of his practice which are false, misleading and deceptive by implying he is a medical physician. Based on the foregoing, Respondent is subject to discipline pursuant to Section 464.018(1)(g), Florida Statutes. COUNT II Petitioner realleges Paragraphs 1-7 as if set forth below. Respondent has caused to be distributed a handbill or flyer which purports to advertise his presentation of seminars/workshops on aromatherapy and his availability for individual consultation and treatment. Said handbill or flyer is false, misleading or deceptive by implying Respondent is a medical physician. Based on the foregoing, Respondent is subject to discipline pursuant to Section 464.018(1)(g). Florida Statutes. , ) - COUNT Ill Petitioner realleges Paragraphs 1-11 as if set forth below. Said handbill or flyer implies patients can “witness miracles” through’ the treatments Respondent provides and/or teaches. | 14. Based on the foregoing, Respondent is subject to discipline pursuant to Section 464.018(1)(g), Florida Statutes. WHEREFORE, Petitioner respectfully requests 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, placernent of the Respondent on probation, costs, and/or any other relief that the Board deems appropriate. Signed nro tray of , 2001. obert G. Brooks, M.D. Secretary, Department of Health Naney Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL FOR THE PETITIONER: oceuh LED James A. Bordonaro ry te AEALTH _ Fla. Bar No. 129471 CLERK WH: Post Office Box 14229 ; hihi. Cero, Tallahassee, Florida 32317-4229 _ DATEL @ [ Se, (850) 410-0621 - ~ ME vL« , fers /

Docket for Case No: 01-003759PL