STATE OF FLORIDA AGENCY FOR HEALTH CARE ADMINISTRATION ey STATE OF FLORIDA AGENCY FOR HEALTH CARE ADMINISTRATION, Petitioner, ee et vs. AHCA No: 2003005908 Return Receipt Requested GOLDEN GIRLS NURSE REGISTRY, 7002 2410 0001 4236 8994 INC., d/b/a GOLDEN GIRLS 7002 2410 0001 4236 9007 NURSE REGISTRY, INC., Respondent / ADMINISTRATIVE COMPLAINT COMES NOW the Agency for Health Care Administration (hereinafter “AHCA” or the “Agency”), by and through the undersigned counsel, and files this Administrative Complaint against Golden Girls Nurse Registry, Inc., d/b/a Golden Girls Nurse Registry, Inc. (hereinafter “Golden Girls Nurse Registry, Inc.” or the “registry”) pursuant to 28-106.111, Florida Administration Code (2002) (hereinafter “PLALC.”), and Chapter 120, Florida Statutes (2002) (hereinafter “Fla. Stat.”), and alleges: NATURE OF ACTION 1. This is an action to impose and maintain the Agency’s administrative fine in the amount of $1,000.00, pursuant to Sections 400.484, 400.506, Fla. Stat., and Rule 59A-18.016, Florida Administrative Code (“F.A.C.”). JURISDICTION AND VENUE 2. This Court has jurisdiction pursuant to Section 120.569 and 120.57, Fla. Stat., and Chapter 28-106, F.A.C. 3. venue lies in Palm Beach County, pursuant to 120.57, Fla. Stat., and Chapter 28-106.207, F.A.C. PARTIES 4. AHCA is the enforcing authority with regard to home health agencies licensure law, pursuant to Chapter 400, Part IV, Fla. Stat., and Rules 59A-18, F.A.C. 5. Golden Girls Nurse Registry, Inc. is a nurses registry agency located at 12794 Forest Hill Blvd., Wellington, Florida 33414, and is licensed under Chapter 400, Part IV, Fla. Stat., and Chapter 59A-18, F.A.C.; license number 30210960. COUNT I GOLDEN GIRLS NURSE REGISTRY, INC. FAILED TO ENSURE THAT MEDICATIONS AND TREATMENTS WERE PROVIDED BY QUALIFIED PERSONNEL, IN THAT BLOOD SUGAR CHECKS AND INSULIN INJECTIONS WERE ADMINISTERED BY A HOMEMAKER/COMPANION AND NOT LICENSED PERSONNEL. Sections 400.506(11), 400.462(5) and (18), Fla. Stat., and 59A-18.009(3) (a-f), F.A.C. (COMPANIONS) CLASS II DEFICIENCY 6. AHCA re-alleges and incorporates paragraphs (1) through (5) as if fully set forth herein. 7. During the survey conducted by the Agency on 7/09/2003 and based on facility records and_= staff interviews, the Agency found that Golden Girls Nurse Registry, Inc. failed to ensure that medications and treatments were provided by qualified personnel, in that blood sugar checks and insulin injections were administered by a homemaker/companion and not licensed personnel. The Agency found that the facility did not ensure that companions did not provide "hands on" care to one client (#5). Findings include the following, to wit: (a) Client #5 had a start of care date of 2/10/03. This client had diagnoses of Insulin dependent diabetes, dementia, was legally blind in the right eye, glaucoma, and a hiatal hernia. (b) In the nurses’ notes of 2/13/03, the notes read, "Resident states he does not use his finger tips due to numbness. Also states he does not feel comfortable giving himself eye drops or insulin injections” (c) Nurses notes of 2/20/03 state, "Resident companion, G-----, started employment this A.M. Companion has knowledge of insulin injections and stated he has given insulin injections. Writer (RN) reviewed administration of we insulin injection and companion demonstrated procedure safely." (ad) Nurses notes of 2/23/03 indicate, "companion notified writer of increased Blood Sugar" (e) Nurses notes of 5-02-03 state, "diabetic monitoring and injections under the supervision of a registered nurse”. (f) The family of this resident, during a phone interview conducted on 7/08/03, stated that most of the injections were being given by the companion/sitter except for the first 10 days. There were no notes from the companion in the clinical folder; only notes from the nurse. (g) Facility representatives were not able to comment on this situation and were unable to produce any notes written by the companion/sitter or a file for the companion/sitter. 8. Based on the foregoing, Golden Girls Nurse Registry, Inc. violated Sections 400.506(11), 400.462(5) (18), Fla. Stat., herein classified as a Class I! deficiency, pursuant to Section 400.484, Fla. Stat., and Rule 59A-18.016, F.A.C., which carries a $1,000.00 fine. PRAYER FOR RELIEF WHEREFORE, the Petitioner, State of Florida Agency for Health Care Administration requests the following relief: A. Make factual and legal findings in favor of the Agency on Count I. B. Assess and maintain the Agency’ s administrative fine of $1,000.00 against Golden Girls Nurse Registry, Inc., in accordance with §400.484, §400.506, Fla. Stat. and Rule 59A-18.016, F.A.C. Cc. Award the Agency for Health Care Administration reasonable attorney’s fees, expenses, and costs, if the Court finds that costs are applicable, and D. Grant such other relief as this Court deems is just and proper. Respondent is notified that it has a right to request an administrative hearing pursuant to Sections 120.569 and 120.57, Florida Statutes. (2002). Specific options for administrative action are set out in the attached Election of Rights and explained in the attached Explanation of Rights. All requests for hearing shall be made to the Agency for Health Care Administration, and delivered to the Agency for Health Care Administration, Agency Clerk, 2727 Mahan Drive, Building 3, Mail Stop #3, Tallahassee, Florida 32308. RESPONDENT IS FURTHER NOTIFIED THAT THE FAILURE TO RECEIVE A REQUEST FOR A HEARING WITHIN TWENTY-ONE (21) DAYS OF RECEIPT OF THIS COMPLAINT, PURSUANT TO THE ATTACHED ELECTION OF RIGHTS, WILL RESULT IN AN ADMISSION OF THE FACTS ALLEGED IN THE COMPLAINT AND THE ENTRY OF A FINAL ORDER BY THE AGENCY. Respectfully submitted, ~ or Of rn, “ ‘ eed eo {s Kathryn F. Fenske, Esq. Assistant General Counsel Agency for Health Care Administration Florida Bar No. 0142832 8355 NW 53°° Street, 1°* Floor Miami, Florida 33166 (305) 499-2165 Copies to: Kathryn F. Fenske, Assistant General Counsel Agency for Health Care Administration Manchester Building 8355 NW 53°° Street Miami, Florida 33166 Elizabeth Dudek, Deputy Secretary Agency for Health Care Administration 2727 Mahan Drive, MS#9 Tallahassee, Florida Diane Reiland, Field Office Manger Agency for Health Care Administration 1710 East Tiffany Drive, Suite 100 West Palm Beach, Florida 33407 6 Jean Lombardi Finance and Accounting Agency for Health Care Administration 2727 Mahan Drive, Mail Stop #14 Tallahassee, Florida 32308 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Certified Mail, Return Receipt Requested to Jean Elizabeth Berger, Administrator, Golden Girls Nurse Registry, Inc., 12794 Forest Hill Blvd., Wellington, Florida 33414, and to Ss. Steinberger, Registered Agent, 12794 Forest Hill Blvd., Suite 1-B, Wellington, Florida 33414 on ( lug: 2%, 2003. Kathfyn F. Fenske, Esq. IN THE COUNTY COURT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: GOLDEN GIRLS NURSE REGISTRY, INC., Plaintiff, > KEITH E. ROBINSON and VIRGINIA , S ROBINSON WOODWARD, ™ ce Defendant. / COMPLAINT. COMES NOW the Plaintiff, GOLDEN GIRLS NURSE REGISTRY, INC., and sues the Defendants, KEITH E. ROBINSON and VIRGINIA ROBINSON WOODWARD, and would state: 1. This is an action for damages less than $15,000.00, exclusive of costs, interest and .. attorneys’ fees. 2. The Plaintiff (hereinafter “GOLDEN GIRLS”) is a Florida corporation doing business in Palm Beach County, Florida. 3. The Defendant, KEITH E. ROBINSON (hereinafter “ROBINSON”) is over the age of 18 and resides in Jupiter, Palm Beach County, Florida. 4. The Defendant, VIRGINIA ROBINSON WOODWARD (hereinafter “WOODWARD” is over the age of 18 and resides in Palm Beach County, Florida. 5. Venue is proper in Palm Beach County, Florida, to the extent that the obligations arose in Palm Beach County, Florida and were to be paid at GOLDEN GIRLS’ place of business in Palm Beach County, Florida, and to the extent that the Defendant resides in Palm Beach County, Florida. COUNT I - BREACH OF CONTRACT 6. The allegations contained in Paragraphs 1 through 5 are realized as if fully set forth herein. 7. On or about February 10, 2003, ROBINSON entered into a Consent and Service Agreement (hereinafter the “ Agreement”) with GOLDEN GIRLS to perform nursing services, a true and correct copy of the Agreement is attached hereto as Exhibit “A”. 8. GOLDEN GIRLS performed the work required under the Agreement, and complied " with all conditions precedent for bringing this action. 9. ROBINSON breached the Contract by failing to pay GOLDEN GIRLS under the Agreement in the amount of $13,200.00. 10. The original amount due and owing is $17,680.00 pursuant to the Invoices attached hereto as Exhibit ““B”. 11. GOLDEN GIRLS is in receipt of payments in the total amount of $4,480.00, copies attached hereto as Exhibit “C”, thereby reducing the amount due to $13,200.00. 12. GOLDEN GIRLS is entitled to attorney's fees under the terms of the Agreement attached hereto as Exhibit “A”, if necessary. WHEREFORE, the Plaintiff, GOLDEN GIRLS NURSE REGISTRY, INC., seeks a judgment against the Defendant, KEITH E. ROBINSON, for damages, plus costs, attorney's fees under the Agreement, interest and such other relief that the Court may deem appropriate. COUNT I - OPEN ACCOUNT 13. The allegations of Paragraphs | through 5 are realleged as if fully set forth herein. 14. ROBINSON owes GOLDEN GIRLS the sum of $13,200.00, which is due with interest since May 30, 2003, according to the invoices attached hereto as Exhibit “B” after reduction for the payments referenced in Exhibit “C”’ attached. WHEREFORE, the Plaintiff, GOLDEN GIRLS NURSE REGISTRY, INC., demands a judgment against the Defendant, KEITH E. ROBINSON, for damages, plus costs, interest, and such other relief as this Court may deem appropriate. COUNT HI - ACCOUNT STATED 15. The allegations of Paragraphs 1 through 5 are realleged as if fully set forth herein. 16. Before the institution of this action, GOLDEN GIRLS and ROBINSON had business transactions between them and on May 30, 2003 agreed to a resulting balance. 17. GOLDEN GIRLS rendered its invoices to ROBINSON, copies being attached hereto as Exhibit “B”, and ROBINSON did not object to the invoices. 18. ROBINSON owes GOLDEN GIRLS the sum of $13,200.00, which is due with interest since May 30, 2003 on the account after reduction for the payments referenced in Exhibit “C” attached. WHEREFORE, the Plaintiff, GOLDEN GIRLS NURSE REGISTRY, INC., demands a judgment against the Defendant, KEITH E. ROBINSON, for damages, plus costs, interest, and such other relief as this Court may deem appropriate. COUNT TV - QUANTUM MERUIT 19, The allegations of paragraphs 1 through 5 are realleged as if fully set forth herein. 20. ROBINSON requested GOLDEN GIRLS to perform services. 21. GOLDEN GIRLS performed services requested. 22. GOLDEN GIRLS provided invoices for the services, copies of which are attached hereto as Exhibit “B”. 23. GOLDEN GIRLS is entitled to recover the reasonable value of the services. 24. | ROBINSON would be unjustly enriched if ROBINSON was allowed to order the services and request the services, but failed to pay the reasonable value for the services. 25. There is no adequate remedy at law. WHEREFORE, the Plaintiff, GOLDEN GIRLS NURSE REGISTRY, INC., demands a judgment against the Defendant, KEITH E. ROBINSON, for the reasonable value the services, plus costs, interest, and such other relief as this Court may deem appropriate. COUNT V - BREACH OF GUARANTEE 26. The allegations of Paragraphs 1 through 5 are realleged as if fully set forth herein. 27, At all times material hereto, WOODWARD handled all aspects of the business dealings between GOLDEN GIRLS and ROBINSON, including: A. requesting services B. dealing with billing information C. dealing with service issues D. paying bills 28, Inaddition, WOODWARD (the sister of ROBINSON), at all times functioned under a Durable Power of Attorney in dealing with issues relating to ROBINSON’S care. 29. During the course of dealings, GOLDEN GIRLS received assurances from WOODWARD directly or through her husband, WILLIAM McGILL WOODWARD JR., that WOODWARD would make sure that GOLDEN GIRLS was paid for services being performed. 30. . WOODWARD complied with promises of payment on several occasions as evidenced by the checks drawn on WOODWARD’S personal bank account (See Exhibit “C” attached). 31. Inreliance upon the assurances of WOODWARD that she would make sure the bills would get paid and WOODWARD ’S actions in paying invoices, GOLDEN GIRLS continued to perform work. 32. It would be unjust and unfair to allow WOODWARD to obtain the nursing services requested based upon promises that the bills would be paid and then to cease paying bills for work performed in reliance of the payment promises made by WOODWARD. 33. GOLDEN GIRLS seeks recovery against WOODWARD in that WOODWARD specifically promised that the pills would be paid in order to induce GOLDEN GIRLS to continue performing services. 34, Inreliance upon WOODWARD’S promises GOLDEN GIRLS continued to provide nursing care even though payments were not forthcoming directly from the state of North Carolina on behalf of ROBINSON. 35. After rendering services upon reliance of WOODWARD’S promises to pay oT to make sure that the bills got paid, a balance of $13,200 remains unpaid pursuant to the invoices attached hereto as Exhibit “B”. 36. Exhibit “D” is a copy of the letter issued by GOLDEN GIRLS May 29, 2003, to WOODWARD relating to the balance due and owing. 5 37. There is no adequate remedy law and WOODWARD should be held accountable for promising to make payment and should be responsible for the unpaid bills relating to services provided on the basis of her statements and actions. WHEREFORE, the Plaintiff, GOLDEN GIRLS NURSE REGISTRY, INC., seeks a Judgment against the Defendant, VIRGINIA ROBINSON WOODWARD, for damages plus costs, interest, and such other relief this court may deem appropriate. DATED this A day of June, 2003. KEVIN D. WILKINSON, P.A. Attomeys for Plaintiff 12794 West Forest Hill Boulevard Suite 28B Wellington, Florida 33414 (561) 753-7200 ives BY* Kevin D. Wilkinson, Esquire Florida Bar No. 332100 Golden Girls Nurse Regisiry, Inc. 12794 W Forest Hill Bivd., Suite 1-B Wellington, FL 33414 oe Phone: 561-795-4667 Fax: 561-795-5940 be Consent and Service Agreement Patient Name_ Koh; er = Date of Service_%//0 Joz Me: / fe The sub-contractor assigned to you will submit a time slip designating the days and hours worked. It is very important for you to review and sign the time slip and retain the pink copy for your records. You should never pay our sub-contractor directly or make any loan, gifts, or advances of money to them. If you desire to change the hours or the type of services that have been scheduled, please call the office. As a company policy, we charge time and one-half for the following holidays: New Year's Day, Memorial Day, July 4th, Labor Day, Thanksgiving Day and Christmas Day. Authorization for Treatment: | (we) hereby authorize Golden Girls Nurse Registry, Inc. to provide the following services to me or, upon my authority, to the above named patient. | (we) acknowledge that no guarantee or warranty has been made to me as the result of any treatment, procedure or service which may be given or performed. | (we) understand that the services provided by Golden Girls Nurse Registry, Inc. are not covered by Medicare or Medicaid. of. Your charge will be based on the prevailing rates for services rendered which are: / bb. gabe Bex Financial Agreement: | understand that | am financially responsible for all charges for services rendered at the rate described above. | (we) understand the unpaid accounts will be considered in default after sixty (60) days, after which time interest will be imposed at the rate of 1.5% per month on unpaid balances (ANNUAL PERCENTAGE RATE 18%) or the legal rate whichever is lower. If a legal suit is necessary to enforce payment of this account, | (we) agree to pay such attorney fees and court costs as may be deemed reasonable. | (we) agree to pay the weekly invoice upon receipt. | (we) agree not to employ a Golden Girls Nurse Registry, Inc. sub-contractor for a period of three hundred sixty (360) days following his/her assignment to us. In the event | (we) violate the above condition, | (we) shall pay to Golden Girls Nurse Registry, Inc. the sum of $2500.00 as liquidated damages. All patients must give Golden Girls Nurse Registry, inc. thirty (30) days notice in writing prior to the termination of services. : Insurance Assistance: If the patient has any type of long term care insurance the registry will assist the patient in filing all necessary claims data with the stated insurance company and senda duplicate copy of the required data to the patient. All insurance proceeds will be sent to the patient. This does not allow the patient to withhold the weekly payment for services due the registry until the patient recieves payment on a claim from the insurance company. Authorization to Release Medical Information: Go/den Girls Nurse Registry, Inc. is hereby authorized to disclose ail or any part of the medical record of the above-named patient to insurance companies, or other parties in connection with this account. This authorization is given with full knowledge that such disctosure may contain information of a confidential nature and may result in a denial of insurance coverage for the services rendered by Gaiden Girls Nurse Registry, Inc. THE UNDERSIGNED CERTIFIES THAT HE/SHE HAS READ AND UNDERSTANDS EACH OF THE ABOVE PARAGRAPHS AND IS THE PATIENT OR OTHER RESPONSIBLE PARTY WITH THE PO M Weep. THIS DOCUMENT AND ACCEPT THESE TERMS. irniad ow ‘Rate OL Signature of Witness Signature of Patient or Responsible Party & Date Pre. sn - Lad Lebess herrerare Anos Relationship to Patient ‘olden Girls Nurse Registry, Inc. & Date Signed Golden Girls Nurse Registry, In. . Invoice 12794 W. Forest Hill Bivd., Ste 1-B : Wellington, FL 33414 — : Date |__Involce# (561) 795-4667 FAX (561)-795-5940 5/30/2003 1654 | Toll Free 1-877-687-7320 | Bill To Keith Robmson c/o Virginia Woodard 7100 Eagle Terrace West Palm Beach FL 33412 Account Number Serviced Item Description Qty Rate Amount 5/26/2003 | Nursing Ser... |Holiday: time & 1/2 240.00 | 240.00 5/27/2003 | Nursing Ser... -160.00 | 160.00 5/28/2003 | Nursing Ser... 160.00 | 160.00 5/29/2003 | Nursing Ser... 160.00 | 160.00 5/30/2003 | Nursing Ser... 160.00 160.00 ee eee Total $880.00 | Golden Girls Nurse Registry, Inc. 12794 W. Forest Hill Blvd., Ste.1-B Wellington, FL 33414 (561) 795-4667 FAX (561)-795-5940 Toll Free 1-877-687-7320 Invoice Date Invoice # 5/27/2003 1644 Cs Bill To | ra Keith Robinson ‘> c/o Virginia Woodard o 7100 Eagle Terrace Om, West Palm Beach FL 33412 < ‘oe Account Number Serviced Item Description Qty Rate Amount 5/19/2003 | Nursing Ser... 1] 160.00 160.00 5/20/2003 | Nursing Ser... 1) 160.00 160.00 5/21/2003 | Nursing Ser... 1; 160.00 160.00 5/22/2003 | Nursing Ser... 1; 160.00 160.00 5/23/2003 | Nursing Ser... 1] 160.00 160.00 5/24/2003 | Nursing Ser... 1) 160.00 160.00 $/25/2003 | Nursing Ser... 1; 160.00 160.00 | | Totai | $1,120.00 | Golden Girls Nurse Registry, Inc. 12794 W. Forest Hill Blvd., Ste 1-B Wellington, FL 33414 (561) 795-4667 FAX (561)-795-5940 Toll Free 1-877-687-7320 Invoice Date Invoice # 5/19/2003 1629 Bilt To Q Keith Robinson Oa c/o Virginia Woodard : \ 7100 Eagle Terrace - West Palm Beach FL 33412 “oO \ ae Account Number . Serviced Item Description Qty Rate Amount 5/12/2003 | Nursing Ser... 1} 160.00 160.00 5/13/2003 | Nursing Ser... 1; 160.00 160.00 5/14/2003 | Nursing Ser... 1} 160.00 160.00 5/15/2003 | Nursing Ser... 1; 160.00 160.00 5/16/2003 |Nursing Ser... 1} 160.00 160.00 5/17/2003 | Nursing Ser... 1) 160.00 160.00 5/18/2003 | Nursing Ser... 1; 160.00 160.00 i | | | | Total $1,120.00 | Golden Girls Nurse Registry, Inc. : ] nvo i ce 12794 W. Forest Hill Bivd., Ste 1-B Wellington, FL 33414 | Date Invoice # (561) 795-4667 FAX (561)-795-5940 . | 5/12/2003 1613 Toll Free 1-877-687-7320 : “ Bill To - - Keith Robmson : - c/o Virginia Woodard — 7100 Eagle Terrace am West Palm Beach FL 33412 ae . eA > Account Number Serviced | Item Description Qty Rate ] Amount 160.00 160.00 160.00 160.00 160.00 160.00 160.00 160.00 160.00 160.00 160.00 160.00 160.00 5/5/2003 | Nursing Ser... 5/6/2003 | Nursing Ser... 5/7/2003 | Nursing Ser... 5/8/2003 | Nursing Ser... 5/9/2003 | Nursing Ser... 5/10/2003 | Nursing Ser... 5/11/2003 | Nursing Ser... ee i cl an So fon) oO Total $1,120.00 | Golden Girls Nurse Registry, Inc. 12794 W. Forest Hill Blvd., Ste 1-B Invoice Wellington, FL 33414 Date Invoice # (561) 795-4667 FAX (561)-795-5940 5/2/2003 1570 Toll Free 1-877-687-7320 2 Bill To f, : € Keith Robinson ee c/o Virginia Woodard . 7100 Eagle Terrace Aa West Palm Beach FL 33412 wy Account Number Serviced Item Description Qty Rate | Amount 4/28/2003 | Nursing Ser... 1; 160.00 160.00 4/29/2003 | Nursing Ser... 1} 160.00 160.00 4/30/2003 | Nursing Ser... 1} 160.00 160.00 5/1/2003 | Nursing Ser... 1} 160.00 160.00 5/2/2003 | Nursing Ser... 1) 160.00 160.00 5/3/2003 | Nursing Ser... 1} 160.00 160.00 5/4/2003 | Nursing Ser... 1} 160.00 160.00 ] Total $1,120.00 if i | Golden Girls Nurse Registry, Inc. Invo i ce 12794 W. Forest Hill Blvd., Ste 1-B Wellington, FL 33414 Date Invoice # (561) 795-4667 FAX (561)-795-5940 Toll Free 1-877-687-7320 4/28/2003 1552 Bill To oy Keith Robinson oan c/o Virginia Woodard “ 7100 Eagle Terrace oo West Palm Beach FL 33412 LL ; Account Number Serviced ttem Description Qty Rate Amount 4/22/2003 | Nursing Ser... 1} 160.00 160.00 4/23/2003 | Nursing Ser... 1} 160.00 160.00 4/24/2003 |Nursing Ser... 1| 160.00 160.00 4/25/2003 | Nursing Ser... 1 160.00 160.00 4/26/2003 | Nursing Ser... 1] 160.00 160.00 4/27/2003 | Nursing Ser... 1} 160.00 160.00 Total ! Golden Girls Nurse Registry, Inc. Invoice 12794 W. Forest Hill Blvd., Ste 1-B- Wellington, FL 33414 Date Invoice # (561) 795-4667 FAX (561)-795-5940 4/21/2003 1513 Toll Free 1-877-687-7320 Bill To | e Keith Robinson ‘ : ; c/o Virginia Woodard . 7100 Eagle Terrace we West Palm Beach FL 33412 “O. Account Number Serviced Item Description Qty Rate Amount 4/17/2003 {Nursing Ser... 1} 160.00 160.00 4/18/2003 | Nursing Ser... 1; 160.00 160.00 4/19/2003 | Nursing Ser... 1} 160.00 160.00 4/20/2003 | Nursing Ser... 1} 160.00 160.00 4/21/2003 {Nursing Ser... 1; 160.00 160.00 | Total $800.00 | Golden Girls Nurse Registry, Inc. 12794 W. Forest Hill Blvd., Ste 1-B Wellington, FL 33414 (561) 795-4667 FAX (561)-795-5940 Invoice Date Invoice # | 4/14/2003; 1511 | Toll Free 1-877-687-7320 | oO, Bill To a Keith Robinson z : c/o Virginia Woodard s 7100 Eagle Terrace West Palm Beach FL 33412 7” Account Number Serviced Item Description Qty Rate Amount 4/14/2003 | Nursing Ser... 1; 160.00 160.00 4/15/2003 | Nursing Ser... 1} 160.00 160.00 4/16/2003 | Nursing Ser... 1} 160.00 160.00 Total $480.00 | Golden Girls Nurse Registry, Inc. 12794 W. Forest Hill Blvd., Ste ]-B. Wellington, FL 33414 (561) 795-4667 FAX (561)-795-5940 Toll Free 1-877-687-7320 Invoice Date Invoice # 4/14/2003 1510 Bill To | Keith Robinson SS c/o Virginia Woodard n can 7100 Eagle Terrace 2 “C. West Palm Beach FL 33412 cs me Account Number Serviced Item Description Qty Rate Amount 4/7/2003 | Nursing Ser... 1; 160.00 160.00 4/8/2003 | Nursing Ser... 1} 160.00 160.00 4/9/2003 | Nursing Ser... 1; 160.00 160.00 4/10/2003 | Nursing Ser... 1} 160.00 160.00 4/11/2003 | Nursing Ser... 1; 160.00 160.00 4/12/2003 | Nursing Ser... 1} 160.00 160.00 4/13/2003 | Nursing Ser... 1} 160.00 160.00 i 1 Total $1,120.00 | Golden Girls Nurse Registry, Inc. 12794 W. Forest Hill Blvd., Ste 1-B Wellington, FL 33414 (561) 795-4667 FAX (561)-795-5940 Toll Free 1-877-687-7320 Invoice Date Invoice # 1509 4/7/2003 sae i) Bill To 4 Keith Robinson vO c/o Virginia Woodard a 7100 Eagle Terrace oe West Palm Beach FL 33412 . Account Number Serviced Item Description Qty Rate Amount 3/31/2003 | Nursing Ser... 1; 160.00 160.00 4/1/2003 | Nursing Ser... 1} 160.00 160.00 4/2/2003 | Nursing Ser... 1} 160.00 160.00 4/3/2003 | Nursing Ser... 1; 160.00 160.00 4/4/2003 | Nursing Ser... 1; 160.00 160.00 4/5/2003 _ | Nursing Ser... 1} 160.00 160.00 4/6/2003 _| Nursing Ser... 1; 160.00 160.00 Total $1,120.00 , Golden Girls Nurse Registry, Inc. 12794 W. Forest Hill Blvd., Ste 1-B Wellington, FL 33414 (561) 795-4667 FAX (561)-795-5940 Toll Free 1-877-687-7320 Bill To Keith Robinson Ste 1411 110 Mangrove Bay Jupiter, FL 33477 donde oth BLL Tet Virginia Woodward 7100 Eagle Terrace West Palm Beach FL 33412 Invoice Date invoice # 3/31/2003} 1440 Account Number Serviced item 3/24/2003 | Nursing Ser... 3/25/2003 | Nursing Ser... 3/26/2003 | Nursing Ser... 3/27/2003 | Nursing Ser... 3/28/2003 | Nursing Ser... 3/29/2003 | Nursing Ser... 3/30/2003 | Nursing Ser... Description Rate Amount 160.00 160.00 160.00 160.00 160.00 160.00 160.00 160.00 160.00 160.00 160.00 160.00 160.00 160.00 Total $1,120.00 | Golden Girls Nurse Registry, Inv | nvo i ce 12794 W. Forest Hill Blvd., Ste 1-B Wellington, FL 33414 | | pate | inveicee (561) 795-4667 FAX (561)-795-5940 3724/2003) 1424 Toll Free 1-877-687-7320 2; Bill To - Keith Robinson , Ste 1411 - 110 Mangrove Bay ite Jupiter, FL 33477 we 2 Account Number t+ Serviced Item Description Qty Rate Amount 160.00 160.00 160.00 160.00 160.00 160.00 . 160.00 160.00 160.00 160.00 160.00 160.00 160.00 3/17/2003 | Nursing Ser... 3/18/2003 | Nursing Ser... 3/19/2003 | Nursing Ser... 3/20/2003 {Nursing Ser... 3/21/2003 | Nursing Ser... 3/22/2003 | Nursing Ser... 3/23/2003 | Nursing Ser... oll el oe ee _ an oO Oo Oo Total $1,120.00 Golden Girls Nurse Registry, Inc. ~ 12794 W. Forest Hill Blvd., Ste 1-B Wellington, FL 33414 (561) 795-4667 FAX (561)-795-5940 Toll Free 1-877-687-7320 [ea To invoice Date 3/17/2003 Invoice # 1404 | Keith Robinson Ste 1411 110 Mangrove Bay Oct . Jupiter FL 33477 te Account Number Serviced Item Description Qty Rate Amount 3/10/2003 | Nursing Ser... 1! 160.00 160.00 3/11/2003 | Nursing Ser... 1} 160.00 160.00 3/12/2003 | Nursing Ser... 1; 160.00 160.00 3/13/2003 |Nursing Ser... 1; 160.00 160.00 3/14/2003 | Nursing Ser... 1} 160.00 160.00 3/15/2003 {Nursing Ser... 1; 160.00 160.00 3/16/2003 | Nursing Ser... 1} 160.00 160.00 i | , Total $1,120.00. | Total Golden Girls Nurse Registry, Inc. ~ Inv oice 12794 W. Forest Hill Bivd., Ste 1-B ~ Wellington, FL 33414 Date invoice # (561) 795-4667 FAX (561)-795-5940 3/10/2003 1427 Toll Free 1-877-687-7320 : —— es Bill To ot Keith Robinson . . Ste 1411 ‘ _ 110 Mangrove Bay ~ Jupiter FL 33477 2, i Account Number Serviced ie Item Description Qty Rate Amount -|3/3/2003 | Nursing Ser... 1} 160.00 160.00 3/4/2003 Nursing Ser... 1) 160.00 160.00 3/5/2003 Nursing Ser... 1} 160.00 - 160.00 3/6/2003 | Nursing Ser... 1} 160.00 160.00 3/7/2003 | Nursing Ser... 1; 160.00 160.00 3/8/2003 | Nursing Ser... 310 jo 1\\ 160.00 160.00 3/9/2003 | Nursing Ser... 1} 160.00 160.00 | . 507 ~ [Ie | ce al? $1;120.00. | Golden Girls Nurse Registry, Inc. ~ 12794 W. Forest Hill Blvd., Ste 1-B Wellington, FL 33414 (561) 795-4667 FAX (561)-795-5940 Toll Free 1-877-687-7320 Bill To Keith Robinson Ste 1411 110 Mangrove Bay Jupiter FL 33477 Invoice Date | Invoice # 3/4/2003 1411 2/24/2003 2/25/2003 2/26/2003 2/27/2003 2/28/2003 3/1/2003 3/2/2003 Nursing Ser... Nursing Ser... Nursing Ser... Nursing Ser... Nursing Ser... Nursing Ser... Nursing Ser... t i Description | We appreciate your prompt payment. Qty ee eres Account Number | Rate Amount 160.00 160.00 160.00 160.00 160.00 160.00 160.00 160.00 160.00 160.00 160.00 160.00 160.00 Total... $1,120.00. Golden Girls Nurse Registry, In. ~ 7 12794 W. Forest Hill Blvd., Ste 1B Wellington, FL 33414 (561) 795-4667 FAX (561)-795-5949 Toll Free 1- -877-687-7320 Keith Robinson Ste 1411 110 Mangrove Bay Jupiter FL 33477 Account Number 2/17/2003 2/18/2003 -_ 2/19/2003 Nursing Ser... 2/20/2003 Nursing Ser... 2/21/2003 Nursing Ser... 2/22/2003 Nursing Ser... 2/23/2003 Nursing Ser... 1 1 . . 1; 160.00 |” 160.00 1} 160.00 160.00 1 1 1 160.00 160.00 160.00 160.00 $1,120.00 Golden Girls Nurse Registry, Inc. ~ Invoice 12794 W. Forest Hill Blvd., Ste 1-B Wellington, FL 33414 Date invoice # (561) 795-4667/ 1-877-Nurse 20 2/20/2003 1386 Fax (561) 795-5440 — O, Bill To v Keith Robinson Ste 1411 110 Mangrove Bay 7 Jupiter FL 33477 Fa u om Serviced Item Description Qty Rate Amount 2/10/2003 | Nursing Ser... 1} 160.00 160.00 2/11/2003 | Nursing Ser... 1! 160.00 160.00 2/12/2003 | Nursing Ser... 1; 160.00 160.00 2/13/2003 | Nursing Ser... 1} 160.00 160.00 2/14/2003 | Nursing Ser... 1} 160.00 160.00 2/15/2003 | Nursing Ser... 1} 160.00 160.00 2/16/2003 Nursing Ser... 1 160.00 160.00 A ’ , i _ Total $1,120.00 iL ae S4d) Northern Trust Bank of Florida N.A. Me tesla _ 6568 66-18/530 CC KEITH E. ROBINSON VIRGINIA OODWARD Pay To The / Order Of be re . tr —_> _WWACHOVIA Wachovia Bank, N.A. a Charlotte, NC 28265-0100 3 / “ / ' MemoL acd - L326 / L234 Z Golden Girls Nurse Registry, Inc. « NR# 30210960 : Op “ey 12794 W. Forest Hill Blvd., 110 Mangrove Bay Way” * Ste 1B 2™* Floor, Ste 1213A Wellington FL 33414 Jupiter FL 33477 Phone: 561-795-4667 Phone 561-744-9211 Fax: 561-795-5940 Fax 561-747-7433 May 29, 2003 Virginia Woodward 7100 Eagle Terrace West Palm Beach FL 33412 RE: Keith Robinson Dear Ms. Woodward: Please be advised effective the evening of Friday, May 30 2003, Golden Girls Nurse Registry will no longer provide services for Mr. Keith Robinson due to non payment. Current balance due effective through end of care 5/30/03 is $13,200.00. Please pay this balance upon receipt of final invoice. We appreciate your prompt attention to this matter. Regards, ; ae ; _f . Liplesg bie? Blaivbergar, garet Steinberger Golden Girls Nurse Registry, Inc. AW IN THE COUNTY COURT IN ¢ AND FOR PALM BEACH COUNTY, ws a Cl van) GOLDEN GIRLS NURSE REGISTRY, ) ) INC., 7 Plaintiff, ) ie an Vv. ) , KEITH E. ROBINSON and ) ANSWER VIRGINIA ROBINSON WOODWARD, ) JURY TRIAL DEMANDED Defendant. ) ) The defendant Virginia Robinson Woodward, above named, answering the Complaint of the plaintiff, above named, alleges and says as follows: 1, Thatthe defendant lacks sufficient information to form a belief as to the allegations of paragraph 1 of the Complaint. 2. That the defendant admits the allegations of paragraph 2 of the Complaint. 3. That the defendant admits the allegations contained in paragraph 3 of the Complaint. 4. That the defendant admits the allegations contained in paragraph 4 of the Complaint. 5. That the allegations of paragraph 5 are conclusions of law and the defendant is not required to answer the same. 6. Yn response to the allegations of paragraph 6, the defendant hereby tealleges and incorporates by reference paragraphs 1 through 5 as fully and effectively as if set forth herein verbatim. 7. That the defendant lacks sufficient information to form a belief as to the allegations of paragraph 7 of the Complaint. 10. 11. 12. 13. 14. 15. 16. That the defendant lacks sufficient information to form a belief as to the allegations of paragraph 8 of the Complaint. That the defendant denies the allegations contained in paragraph 9 of the Complaint. That the defendant denies the allegations contained in paragraph 10 of the Complaint as said amount pertains to this Defendant. That the Defendant admits so much of the allegations of paragraph 11 of the Complaint as pertains to Defendant Woodward having paid a total of $4,480.00 to Plaintiff for the care of her brother, but denies the remaining allegations of paragraph 11 of the Complaint. That the allegations of paragraph 12 are conclusions of law, and the defendant is not required to answer the same. In response to the allegations of paragraph 13, the defendant hereby realleges and incorporates by reference paragraphs 1 through 12 as fully and effectively as if set forth herein verbatim. That the defendant denies the allegations contained in paragraph 14 of the Complaint. In response to the allegations of paragraph 15, the defendant hereby realleges and incorporates by reference paragraphs 1 through 14 as fully and effectively as if set forth herein verbatim. That the Defendant admits so much of the allegations of paragraph 16 of the Complaint as allege that Defendant Woodward paid certain sums to the Plaintiff for the care of her brother, but denies the remaining allegations. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. That the defendant denies the allegations contained in paragraph 17 of the Complaint. That the defendant denies the allegations contained in paragraph 18 of the Complaint. In response to the allegations of paragraph 19, the defendant hereby realleges and incorporates by reference paragraphs 1 through 18 as fully and effectively as if set forth herein verbatim. That the defendant admits the allegations contained in paragraph 20 of the Complaint. That the defendant denies the allegations contained in paragraph 21 of the Complaint. That the defendant denies the allegations contained in paragraph 22 of the Complaint. That the allegations of paragraph 23 are conclusions of law, and the defendant is not required to answer the same. That the allegations of paragraph 24 are conclusions of law, and the defendant is not required to answer the same. That the allegations of paragraph 25 are conclusions of law, and the defendant is not required to answer the same. In response to the allegations of paragraph 26, the defendant hereby realleges and incorporates by reference paragraphs 1 through 25 as fully and effectively as if set forth herein verbatim. That the defendant denies the allegations contained in paragraph 27 of the Complaint. That the defendant denies the allegations contained in paragraph 28 of the Complaint. That the defendant denies the allegations contained in paragraph 29 of the Complaint. That the defendant admits so much of the allegations contained in paragraph 30 of 31. 32. 33. 34. 35. 36. 37. 38. the Complaint as allege that Defendant Woodward made payments on behalf of her brother, but denies the remaining allegations. That the defendant denies the allegations contained in paragraph 31 of the Complaint. That the allegations of paragraph 32 are conclusions of law, and the defendant is not required to answer the same. That the defendant denies the allegations contained in paragraph 33 of the Complaint. That the defendant denies the allegations contained in paragraph 34 of the Complaint. That the defendant denies the allegations contained in paragraph 35 of the Complaint. That the defendant admits the allegations contained in paragraph 36 of the Complaint. That the allegations of paragraph 37 are conclusions of law, and the defendant is not required to answer the same. That the defendant denies each and every allegation of the Complaint not hereinabove specifically admitted or modified. 7100 Eagle Terrace West Palm Beach, Florida 33412 (561) 776-0457 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing pleading has been served upon opposing counsel by mailing a copy properly addressed and with sufficient postage affixed thereto on this 3 day of July, 2003. 11 IN THE COUNTY COURT IN AND FOR PALM BEACH COUNTY, FLORIDA C/A NO.: 2003CCO15240RL GOLDEN GIRLS NURSE REGISTRY, ) INC, ) : Plaintiff, ) ve ) KEITH E. ROBINSON and y ANSWER VIRGINIA ROBINSON WOODWARD, ) JURY TRIAL DEMANDED Defendant. ) The defendant Keith E. Robinson, above named, answering the Complaint of the plaintiff, above named, alleges and says as follows: 1. That the defendant lacks sufficient information to form a belief as to the allegations of paragraph 1 of the Complaint. That the defendant admits the allegations of paragraph 2 of the Complaint. That the defendant admits the allegations contained in paragraph 3 of the Complaint. That the defendant admits the allegations contained in paragraph 4 of the Complaint. That the allegations of paragraph 5 are conclusions of law, and the defendant is not required to answer the same. In response to the allegations of paragraph 6, the defendant hereby realleges and incorporates by reference paragraphs 1 through 5 as fully and effectively as if set forth herein verbatim. . That the defendant lacks sufficient information to form a belief as to the allegations of paragraph 7 of the Complaint. That the defendant lacks sufficient information to form a belief as to the allegations of je 10. 11. 12, 13. 14, 15. 16. 17. paragraph 8 of the Complaint. That the defendant denies the allegations contained in paragraph 9 of the Complaint. That the defendant denies the allegations contained in paragraph 10 of the Complaint as said amount pertains to this Defendant. That the Defendant admits so much of the allegations of paragraph 11 of the Complaint as pertains to Defendant Woodward having paid a total of $4,480.00 to Plaintiff for the care of her brother, this Defendant, but denies the remaining allegations of paragraph 11 of the Complaint. That the allegations of paragraph 12 are conclusions of law, and the defendant is not required to answer the same. In response to the allegations of paragraph 13, the defendant hereby realleges and incorporates by reference paragraphs | through 12 as fully and effectively as if set forth herein verbatim. That the defendant denies the allegations contained in paragraph 14 of the Complaint. In response to the allegations of paragraph 15, the defendant hereby realleges and incorporates by reference paragraphs | through 14 as fully and effectively as if set forth herein verbatim. That the Defendant admits so much of the allegations of paragraph 16 of the Complaint as allege that Defendant Woodward paid certain sums to the Plaintiff for the care of her brother, this Defendant but denies the remaining allegations. That the defendant denies the allegations contained in paragraph 17 of the Complaint. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. IE That the defendant denies the allegations contained in paragraph 18 of the Complaint. In response to the allegations of paragraph 19, the defendant hereby realleges and incorporates by reference paragraphs 1 through 18 as fully and effectively as if set forth herein verbatim. That the defendant admits the allegations contained in paragraph 20 of the Complaint. That the defendant denies the allegations contained in paragraph 21 of the Complaint. That the defendant denies the allegations contained in paragraph 22 of the Complaint. That the allegations of paragraph 23 are conclusions of law, and the defendant is not required to answer the same. That the allegations of paragraph 24 are conclusions of law, and the defendant is not required to answer the same. That the allegations of paragraph 25 are conclusions of law, and the defendant is not required to answer the same. in response to the allegations of paragraph 26, the defendant hereby realleges and incorporates by reference paragraphs 1 through 25 as fully and effectively as if set forth herein verbatim. That the defendant denies the allegations contained in paragraph 27 of the Complaint. That the defendant denies the allegations contained in paragraph 28 of the Complaint. That the defendant denies the allegations contained in paragraph 29 of the Complaint. That the defendant admits so much of the allegations contained in paragraph 30 of the Complaint as allege that Defendant Woodward made payments on behalf of her 31. 32. 33. 34, 35. 36. 37. 38. brother, this Defendant but denies the remaining allegations. That the defendant denies the allegations contained in paragraph 31 of the Complaint. That the allegations of paragraph 32 are conclusions of law, and the defendant is not required to answer the same. That the defendant denies the allegations contained in paragraph 33 of the Complaint. That the defendant denies the allegations contained in paragraph 34 of the Complaint. That the defendant denies the allegations contained in paragraph 35 of the Complaint. That the defendant admits the allegations contained in paragraph 36 of the Compiaint. That the allegations of paragraph 37 are conclusions of law, and the defendant is not required to answer the same. That the defendant denies each and every allegation of the Complaint not hereinabove specifically admitted or modified. — & . Keith E. Robinson DEFENDANT 110 Mangrove Bay Way Jupiter, Florida 33412 (561) 741-3143 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing pleading has been served upon opposing counsel by mailing a copy, properly addressed and with sufficient postage affixed thereto on this % day of July, 2003.

Docket for Case No: 03-004507