Apr 1 2009 16:13 APR-@1-2089 15:55 AHCA P.@3 STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, Petitioner, v. Case No. 2008-18582 LAVONNE ROSE PANJWANI, R.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 the Respondent, Lavonne Rose Panjwani, R.N. 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) in the State of Florida, having been issued license number RN 9163465. 3. Respondent's address of record is 2415 Clay Court, Longwood, Apr 1 2009 16:13 APR-@1-2089 15:55 AHCA P.a4 Alorida 32779. 4, On or about October 23, 2007, the Board of Nursing filed a final order in case number in 2006-23349 which required Respondent, among other requirements: a. to pay an administrative fine in the amount of $250.00; b. to pay costs in the amount of $571.60; c. to enroll and successfully complete a course in Legal Aspects of Nursing and Ethics in addition to other normally required courses. To submit verification of course content and completion to the Nursing Compliance Officer within 6 months from the date of the final order; and d. to be suspended until she makes payment of the fine and costs imposed by this Final Order and demonstrates compliance with each and every term of the final Order in Case No. 2001-01140 filed on March 22, 2006. 5. On or about August 8, 2008, Respondent had not submitted verification of completion of courses in Legal Aspects of Nursing and Ethics. 6. Section 456.072(1)(q), Florida Statutes (2008), provides that violating a lawful order of the department or board, or failing to comply OOH v. Lavonne Rose Panjwani, RN 72- Case Number: 2008-18582 3:\PSU\Nursing\Maja S. Holman\RNs\ACs\VFO\Lavonne Panjawani\AC.doc Apr 1 2009 16:14 APR-@1-2089 15:56 AHCA P.@S with a lawfully issued subpoena of the department constitutes grounds for discipline by the Board of Nursing. 7. Respondent violated the final order entered in case number 2006-23349 by failing to timely comply with the terms and conditions. 8. Based on the foregoing, Respondent is in violation of Section 456.072(1)(q), Florida Statutes (2008), violating a lawful order of the department or board, or failing to comply with a lawfully issued subpoena of the department. | 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. DOH v. Lavonne Rose Panjwani, RN -3- Case Number: 2008-18582 J:\PSU\Nursing\Maja $. Holman\RNs\ACs\VFO\Lavonne Panjawani\AC.doc Apr 1 2009 16:14 APR-@1-2089 15:56 AHCA P.@6 Ps } | Signed this ©. | “day of [ lL bore , 2007. Ana M. Viamonte Ros, M.D., M.P.H., Si Surgeon General Department of Co Maja S. Holman . waht at Assistant General Counsel OFARTE ERT OR feats = DOH-ProsecutionServices Unit NS 52 Bald Cypress Way, Bin C-65 Tallahassee, FL 32399-3265 Florida Bar #0674648 (850) 245-4640 telephone (850) 245-4683 facsimile [00S ro aera WS Hever: at Bron /MSH DOH v, Lavonne Rose Panjwani, R.N. Case No. 2008-18582 DOH v. Lavonne Rose Panjwani, RN 4- Case Number: 2008-18582 J:\PSU\Nursing\Maja 5. Holman\RNs\ACs\VFO\Lavonne Panjawani\AC.doc Apr 1 2009 16:14 APR-@1-2089 15:56 AHCA Pa? 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. DOH v. Lavonne Rose Panjwani, R.N. Case No, 2008-18582 DOH v. Lavonne Rose Panjwani, RN Case Number: 2008-18582 J:\PSU\Nursing\Maja S. Holraan\RNs\ACs\VFO\Lavonne Panjawani\AC.doc

Docket for Case No: 09-001723PL