Apr 19 2006 12:28 APR-19-28H6 12:42 AHCA P.@3 goon. C STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, v. CASE NO. 2005-62445 JEFFREY MANNY GOLDBERG, R.N., RESPONDENT. DMINI. TIVE INT COMES NOW, Petitioner, Department of Health, by and through its undersigned counsel, and files this Administrative Complaint before the Board of Nursing against Respondent, Jeffrey Manny Goldberg, R.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: % ghapter 456, Florida Statutes; and Chapter 464, Florida Statutes. ' a ed 2, ad all times material to this Complaint, Respondent was a : licensed registered nurse (R.N.) within the state of Florida, having been issued license number RN 3285522. Department of Health v. Jeffrey M, Goldberg, R,N. Case number 2005-62445 JAPSU\Nursing\e, Olie\GOLOBERG-RN-Hraud.reps.doc Apr 19 2006 12:28 APR-19-2686 12:45 AHCA Wg 3, Respondent's address of record is Post Office Box 291771, Fort Lauderdale, Florida 33329, 4. At all times material to this Complaint, Respondent was employed as an R.N. at Medical Staffing Network located in Pompano Beach, Florida. 5. On or about August 22, 2005, the Respondent was asked by his employer to provide documentation to indicate Respondent had completed courses in Basic Cardiac Life Support and Advance Cardiac Life Support. 6 On or about August 22, 2005, the Respondent provided his employer with documentation that indicated Respondent had completed courses in Basic Cardiac Life Support and Advance Cardiac Life Support. a ' 7. The documentation Respondent provided his employer had been altered in that Respondent had not completed courses in Basic Cardiac Life Support and Advance Cardiac Life Support. 8. Section 456.072(1)(a), Florida Statutes (2004), provides that making misleading, deceptive, or fraudulent representations in Department of Health v. Jeffrey M, Goldberg, R.N. Case number 2005-42445 ASP SU\Nursing\E, Ollie\GOLDBERG-RN-fraud.reps.dec APR-19-2086 12:43 AHCA vr Apr 19 2006 12:28 v> or related to the practice of the licensee’s profession constitutes grounds for disciplinary action by the Board of Nursing. 9. Respondent made misleading, deceptive, or fraudulent representations when he supplied his employer with altered documentation that indicated he had completed courses in Basic Cardiac Life Support and Advance Cardiac Life Support. 10. Based on the foregoing, Respondent violated Section 456.072(1)(a), Florida Statutes (2004), by making misleading, deceptive, or fraudulent representations in or related to the practice of the licensee’s profession, WHEREFORE, the Petitioner respectfully requests that the Board of Nursing enter an order imposing one or more of the following penalties: permanent revocation or suspension of Respondent's license, restriction of practice, imposition of an Department of Health v. Jeffrey M. Goldberg, RN. Case number 2005-62445 JAPSU\Nuraing\E, Ollie\GOLOBERG-RN-traud.reps.doc Apr 19 2006 12:29 an APR-19-2886 12:43 AHCA collected, remedial education and/or any other relief that the Board deems appropriate. SIGNED this pe _ day of assim 2008 M. Ron Francois, M.D., M.S.P.H,, Ph.D. Secretary, Department of Health FILED Ollie fa - i DEPARTMENT OF HEALTK Assistant General Counsel UTY CLERK DOH Prosecution Services Unit CLERK we Mek 4052 Bald Cypress Way, Bin C-65 DATE {ri -04 Tallahassee, Florida 32399-3265 : Florida Bar No.: 0107792 he (850) 245-4640 Telephone (850) 245-4683 Facsimile. OE/oe Cy Reviewed and approved by: (initials) _12-1$<5 (date) PCP: IHG PCP Members: Hy eG ; eo Department of Health v. Jeffrey M. Goldberg, RN. Case number 2005-62445 JAPSU\WNurslng\E, Ollie\GOLOBERG-| RN-fraud.reps. dog Apr 19 2006 12:29 APR-19-2086 12:43 _ AACA P.B? bey Cc 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. Department of Health v, Jeffrey M. Goldberg, LN, Cage number 2005-62445 APS U\NursinglE, Ollle\GOLOBERG-RN-freud,.rapg.doc ek TOTAL F.&?

Docket for Case No: 06-001424PL