STATE OF FLORIDA | DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH Petitioner, vs. Case No. 2000-13824 _ ANGELA LAND, 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, Angela Land, 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 Practical Nurse in the State of Florida, having been issued license number 5147907. ) 4. Respondent's last known address is 16034 Penwood Drive, Tampa, FL 33647. Oe Ur RRR REY crore mre OMe rem ort 5. On or about May 5, 2000, while employed by the Favorite Nurses, Respondent practiced below the minimal acceptable standards of prevailing nursing practice, to wit: The Respondent practiced nursing from April 5, 2000 to September 18, 2000 with out a current State of Florida license. 6. 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. signed this ay of | kay ,200_|. Robert G. Brooks, M.D. ED JEPARTMENT OF HEALTH DFPUTY CLERK nerk Yahi R. Enon oate. “P/jo/2 Heaith Care Administration COUNSEL FOR THE PETITIONER: Elizabeth A. Hathaway, Staff Attorney Florida Bar No. 0413143 Sedhuadhicamah auiae.cid tical Adnan a manncnitanasaassaieimnuamaniateadaminaaaaatl I SS AaLA . «_canndhsah aC RRS eeaiadl ot died oc coesecsathak ha ee Agency for Health Care Administration Allied Health Section Post Office Box’14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 EAH/eh PCP: _, DOM: Glade eer " F 3 F i L E E : i E

Docket for Case No: 02-000579PL