STATE OF FLORIDA fs (7 Ey DEPARTMENT OF HEALTH ff o> J DEPARTMENT OF HEALTH C2 JAN 29° AMI: 02 Petitioner, vs. KATHY ANN JAMES, 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 ANN JAMES, 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 26757822. aid cal PERT RRR yn Tretr 4. Respondent's last known address is 3371 SW 20™ Court, Fort Lauderdale, Florida 33312. 5. On or about February 23, 20014, while employed by Meriétial Regional Hospital, Hollywood, Florida, Respondent practiced below the minimal acceptable standards of prevailing nursing practice, to wit: 6. At approximately 11:00 p.m., Respondent was found sitting in a dark surgical suite with only the anesthesia lights on. “7%, Respondent was paged repeatedly over the course of her shift and did not respond. instead, she remained in the surgical suite until approximately 6:00 a.m. Asa result, cases remained unfinished. 8. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, by unprofessional conduct by failing to conform to the minimal acceptable standards of prevailing nursing practice. 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. a a ce CARER RE ro omer rrr reer cry or aor . a a) Signed tis 2lday jess hes 200}. COUNSEL FOR THE PETITIONER: Amy M Pietrodangelo, Attorney FBN: 0514039 Agency for Health Care Administration Practitioner Regulation Post Office Box 14229 _ Tallahassee, Florida 32317-4229 (850) 488-0589 AMP/ap PCP: Cox 44 DOM: sobfpa/o [EIEN CRORE RRR RR EES rE Re MER Or see RTT pee mone comet SOON ERE OST Rm mrrer e msmnge sem = PE REE TE ee TE a

Docket for Case No: 02-000357PL