wt &) i n utd oO STATE OF FLORIDA Pip ED ~. DEPARTMENT OF HEALTH “fee 2 OT Noy : 3 DEPARTMENT OF HEALTH ; 4 PH 3:59 = OIVISIO4 oF Petitioner, ADMINIST RAT) HEARINGS " vs. Case No. 2001-01856 DANA TAYLOR, R.N. Ol- 4U10 CL Respondent. / a, 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, DANA TAYLOR, 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 2816292. Respondent's last known address 3 Ultra Place, Palm Coast, Florida 32164. , Count | 5. On or about 07/99, while employed at Memorial Health Systems, the respondent diverted drugs from her place of employment. 6. Based on the foregoing, Respondent is Subject to discipline pursuant to Section 464.018(1)(i), Florida Statutes, for engaging or attempting to engage in the possession, sale, or distribution of controlled substances as ‘Set forth in Chapter 893, for any other than legitimate purposes authorized by this chapter. Count il 7. On or about 07/99, while employed at Memorial Health Systems, the respondent diverted drugs from her place of employment. 8. On or about 2/23/01, Respondent admitted diversion from her place of employment and subsequently requested to be removed from the IPN due to lack of finances. Due to Respondent's dismissal from IPN participation and noncompliance with monitoring requirements, IPN is unable to provide continuous monitoring and cannot determine Respondent's current ability to Practice nursing safely. 9. Based on the foregoing, Respondent is Subject to discipline pursuant to Section 464.018(1)(j), Florida Statutes, for being unable to practice nursing with reasonable skill and safety to patients by reason of illness or use of wore TE RIE RECT RR we RRR alcohol, drugs, narcotics, or chemicals or any other type of material OF as a result of any mental or physical condition. 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 thigylld Wy of bt A tawkey ,200_| John O, ‘Agwunobi, MD, MBA Acting Secretary, Department of Health Nancy Snurkowski, Chie Attomey On Behalf of the Agency for Health Care Administration COUNSEL FOR THE PETITIONER: FI ED Michael J. Kapperman, Senior Attorney DEPARTME OF HEALTH FBN 879721 ; DEPUTY CLepie Agency for Health Care Administration : CLERK Veh R, kene A Allied Health Section : Post Office Box 14229 DATE HES, [of Tallahassee, Florida 32317-4229 (850) 487-9670 MJK/ PCP: ~ DOM: Court ¢fzfo/ acd PRUE Tre og

Docket for Case No: 01-004410PL