May 30 2006 9:55 MAY-3B-2086 10:09 eHCA | C STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, Vv. CASE NO. 2003-14724 ANNE CADET, L.P.N., 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 Respondent, Ann Cadet, L.P.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 licensed practical nurse (L.P.N.) within the state of Florida, having been issued license number PN 1337781, ade JAPSU\Nursing\judy law\nurses\AC's\LPN's\LPN'S\CADET unpro cond-terrorist.doc May 30 2006 9:55 Cc MAY-38-2886 18:18 AHCA 3. Respondent's address of record is 11797 NW 30" St., Coral Springs, Florida 33065. 4. At all times material to this Complaint, Respondent was employed as a L.P.N. at Regents Park (RP) located in Boca Raton, Florida. 5. On or about May 23, 2003, in the early morning hours, Respondent sprinkled an unknown “white powder substance” in front of three administrative office doors, on the carpet and the. doorknobs. Respondent had been disciplined and was to receive a “15 day suspension” for poor work performance, with possible demotion or termination. 6. On or about May 23, 2003, after staff discovered the powder substance, the emergency response team and fire rescue were summoned. Fire Rescue cordoned off the perimeter of RP awaiting possible medical emergencies or evacuation orders. 7. On or about May 23, 2003, Respondent admitted to an agent from the Palm Beach County Sheriff's Office (PBSO), that she was responsible for the “white powder” and that it was not toxic. She admitted she wanted to disrupt the operation of the facility and she wanted to put - fear into the people she viewed as responsible for her demotion. She admitted that the substance was talcum powder with pepper added. a2. JAPSU\Nursing\judy lawnurses\AC's\LPN's\LPN's\GADET unpro sond-terroriat.doc May 30 2006 9:55 ¢ MAY-38-2886 14:18 AHCA 8. Respondent stated that she never threatened anybody, and she wanted to “give them another focus” other than her employment status so she “could keep working.” Respondent showed no concern for the residents of the facility. 9. Asa result of Respondent spreading the white powder at RP, the residents were terrorized and confused, because of the sirens and emergency crews running down the hallways in hazmet suits. They were not able to receive their meals on time, they were evacuated from the facility, corridors were “shut down,” families were unable to contact their loved ones, and fire doors were out of reach due to the hazmat investigation. 10. Section 464.018(1)(n), Florida Statutes (2002), makes it a violation of the Nurse Practice Act to fail to meet minimal standards of acceptable and prevailing nursing practice. 11. Respondent intentionally failed to meet minimal standards of acceptable and prevailing nursing practice by sprinkling white powder substance in the RP facility, thereby disrupting the operation of the facility and the care of the patients. -3- JAPSU\Nursing\udy lawnurses\AC's\LPN's\LPN's\CADET ynpra cond-terroristdoc May 30 2006 9:56 MAY-38-2886 18:18 AHCA om, Cc 12. Based on the foregoing, Respondent is in violation of Section 464.018(1}(n), Florida Statutes (2002), by failing to meet minimal standards of acceptable and prevailing nursing practice. 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 administrative fine, issuance of a reprimand, 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. -4- JAPSU\Nursing\judy law\nurses\AC's\LPN'S\LPN's\CADET unpro cond-terrorist.doc MAY-38-2886 18:11 AHCA May 30 2006 9:56 c SIGNED this day of ___ /favt- John ©, Agwunobi, M.D., M.B.A., M.P.H. Sec q Department of Health FILED - DEPARTMENT OF HEALTH Judith A. Law Bless We kw Assistant General Counsel ee ee pe DOH Prosecution Services Unit pare SS 4052 Bald Cypress Way, Bin C-65 Reviewed and approved by: (/ (initials) 7 ft PCP: le oS vps PCP M Yes Oy lech - %. Hak Tallahassee, Florida 32399-3265 Florida Bar No.: 0881686 (850) 414 — 8126 Telephone (850) 414 — 1991 Facsimile al Anne Cadet, L.P.N. 2003-14724 a5 JAPSU\Nurslng\udy lavAnurses\AC's\LPN's\LPN'S\CADET unpre cond-terrorist.doc May 30 2006 9:56 MAY-38-2886 18:11 AHCA 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. ~6- JAPSU\Nursing\judy law\nurses\AC'S\LPN'S\LPN's\CADET wnipre cond-terrorist,dgc TOTAL F.ae

Docket for Case No: 06-001928PL