STATE OF FLORIDA Pa Dp DEPARTMENT OF HEALTH - 03 JAN -3 PM 3:54 DEPARTMENT OF HEALTH HVE ce . AD ! gf car Petitioner, i af an 68 WE vs. Case No. 2002-04925 MARCUS ADDISON, R.N. (yy COOK PL 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, MARCUS ADDISON, R.N., 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. 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 2795232. 3. Respondent's last known address is 8201 Windson Drive, Hollywood, Florida 33025. 4, On or between November 2001 and February 5, 2002, the Respondent was employed by Bayview Center for Menta! Health, Miami, Florida, as charge nurse. 5. Respondent was observed leaving the facility on numerous occasions for extended periods of time during his shift without proper authorization. 6. On or about January 17, 2002, the while Respondent was absent from the facility, a patient attempted to choke himself. 7. The Respondent could not be reached to help respond to the situation. 8. There was not proper patient supervision during the Respondent's absence. COUNT | 9. The Petitioner realleges and incorporates by reference the foregoing paragraphs as if fully stated herein. 10. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes (2001), by unprofessional conduct for leaving a nursing assignment before properly advising appropriate personnel. COUNT II 11. | Onor about January 7, 2002, the Respondent exposed his penis to another staff member while at the nurse’s station. 12. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes (2001), by unprofessional conduct for failure 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 penaities: 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 Gy of fF O phe. M Pietrodangelo, Attorney FBN: 0514039 Agency for Health Care Administration DEPUTY CLERK / Practitioner Regulation Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 487-9670 AMP/ap , 2002 John O. Agwunobi, MD, MBA Nini, of Health Attorney On Behalf of the Agency for Health Care Administration UNSEL FOR THE PETITIONER: DEPARTMENT OF HEALTH DATE___ Pah o2 mom appa

Docket for Case No: 03-000008PL