SEP-13-28815 1843 ARCA”LEGAL MEDICAL sep 15 2005 10245 . «88 did 1988 P.O STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, vo CASE NO. 2004-25694 KIMBERLY 3.. HOOVER, RN. 7 RESPONDENT. eR ” ADMINISTRATIVE COMPLAINT COMES NOW, Pelitioner, Department of Ilealth, by and through its undersigned counsel, and files this Administrative Complaint before the ‘Board of Nursing against Respondent, Kimberly 1, Hoover, B.N., and in support thereof alleges: 1. Petitioner is the state department charged with regulating the practice of nursing pursuant to Section 20.43, Florida statutes; Chapter 456, Florida Statutes; and Chapter 464, Florida Statutes. 2. At all times material to this Complaint,. Respondent -was a registered nurse (RN) within the state of Florida, having been -issued | ~ fieanse number RN 9165132. tof4 Kimberly J. Hoover, RAN. 2004-75454 SEP-13-2085 18:43 Se : AHCA/“LEGAL MEDICAL p 15 2005 10:44 . 854 aid 1989 P.ar 3. Respondent’s address of record is 87200 Overseas Highway, E- , 1, Tstamorade, Florida 33036. 4. At all-times material to this Complaint, Respondent was employed by Cross Country TravCorps located in Boca Raton, Florida. Cross Country TravCorps provides staff to facilities at a needs basis. 5. “Respondent had been contracted to work at Baptist Hospital South Flotida (BHSF), Respondent had requested a lansfer to another . location, within the BHSF organization. 6. Onor about June 7, 2004, Respondent forged the signature af her BHSF evaluator’s name-on her performance evaluation. . 7. — Section 456.077 (1)(m), Florida Statutes (2003), provides: that . making deceptive, untrue, or fraudulent representations in or related to the . practice of nursing or employing a trick or scheme in or related to the practice of nursing. ; 8. Respondent signed her BHSF evaluator’s hame on her nursing performance evaluation, thereby making a deceptive, untrue, oF fraudulent . representation, . 9, Based on the foregoing, Respondent violated Section 446,072(1)(m), Florida Statutes (2003), by making deceptive, untrue, or . 2af4 Kimberly J. Hoover, RUN., 2004-25804 SEP-13-2085 10:43 Sep 15 2005 10:44 AHCA-LEGAL MEDICAL 858 4i4 1989 Pe . fraudulent representations in or related to the practice of nursing or employing a trick or scheme | in or related to the practice of nursing. WHEREFORE, the Petitioner respectfully requests that the Board of - Nursing cnter an order imposing one or more of the following penalties: permanent revocation or suspension of Respondent's license, restriction of practice, imposition of an administrative tine, issuance of a reprimarid, - placement of the Respondent on probation, ‘corrective action, refund of fees billed or collected, remedial education and/or any other relief that the Board deems appropriate. _ SIGNED this hoa, of F fs « 204. John 0. Agwundty, M.D,, M.B.A., M.P.H. Secreta , Department o of ealth } / fl . FILaD DEPARTMENT OF HEALTH Assistant General Counsel . DEPLITY CLERK DOH Prosecution Services Unit CLERK Nath Colman 4052 Bald Cypress Way, Bin C-65 DATE. Tallahassee, Florida 32399-3265 : Florida Bar No.: 0230560 (850) 414 - 8126 Telephone (850) 414 — 1991 Facsimile /MKS” Reviewed and approved by: DEK (initials) // oF (date) Peres PCP lt 4% qi bacasac, 3of4 Kinberly J. [loover, R.N., 2004-25684 Sep 13 2005 10:44 SEP-13-2085 18:44 854 414 199 ; ] P.@9 AHCA/LEGAL MEDICAL =a. NOTICE OF RIGHTS Respondent has the right to request a hearing to be conducted In accordance with Section 120.569 and 120,57, Florida Statutes, to be represented by counsel or other qualified representative, to present evidence and argument, to call and cross-examine witnesses and to have subpoena and subpoena - duces tecum issued on his or her behalf if a hearing is requested. NOTICE REGARDING ASSESSMENT OF COSTS Respondent is placed on notice that Petitioner has incurred costs related to the investigation and prosecution of this matter. - Pursuant to Section 456,072(4), Florida Statutes, the Board shall assess costs related to the investigation and prosecution of a disciplinary matter, which may include attorney hours and costs, on the Respondent in addition to any other discipline imposed. 4of4 Kimberly J. Hoover, R.N., 2004-25694 TOTAL FP.@o

Docket for Case No: 05-003289PL