Aug 19 2009 13:17 AUIG-19-2889 14°68 AHCA STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, Vv. CASE NO. 2008-22623 CORLEEN ANN MILLER, L.P.N. RESPONDENT. Se 7 ADMINI TIVE 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, Corleen Ann Miller, 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 1353231, 3. Respondent's address of record is 1351 Skylark Court, Deltona, Florida, 32725, AUIG-19-2889 14°68 Aug 19 2009 13:17 AHCA 4. On or about August 21, 2008, Respondent was employed as a L.P.N. in the capacity of Health and Wellness Director by Southland Suites of Longwood at Brookdale Senior Living (Brookdale), located in. Longwood, Florida. 5. On or about August 21, 2008, a certified nursing assistant observed Respondent in Resident C.C’s room at Brookdale, looking through C.C’s wallet while C.C. was on the toilet. 6. Resident C.C. denies giving Respondent permission . to go through C.C.’s wallet, 7. Resident C.C. reported that after Respondent went through C.C’s wallet money missing from the wallet. 8. Respondent took money without authorization from Resident C.C/s wallet, 6. — Section 464.018(1)(h), Florida Statutes (2008), provides that unprofessional conduct, as defined by Board rule, constitutes grounds for disciplinary action by the Board of Nursing. 7. Rule 64B9-8.005(1)(h), Florida Administrative Code, provides that unprofessional! conduct includes stealing from a patient. DOH vy. Carleen Miller, L.P.N. 2 Case No, 2008-13857 J.\PSU\Nursing\Caria Schell\AC\Unprofessional Conduct\Miller RN (stealing from pt).doc Aug 19 2009 13:18 AUIG-19-2889 14:81 AHCA 8. On or about August 21, 2008, Respondent, while working in the capacity of a L.P.N., stole property belonging to Resident C.C. | 9. Based on the foregoing, Respondent violated Section 464.018(1)(h), Florida Statutes (2008), as defined by Rule 64B9- 8.005(1)(h), Florida Administrative Code, to include stealing from a patient. WHEREFORE, 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, thy . SIGNED this_ 29 day of April , 2009. Ana M., Viamonte Ros, M.D., M.P.H. State Surgeon General Carla A. Schell FILED Assistant General Counsel eee EPUTY: CLERK DOH Prosecution Services Unit CLERK Rachel Brooks 4052 Bald Cypress Way, Bin C-65 pate APR 3 0 2005 Tallahassee, Florida 32399-3265 Florida Bar Number 0042155 (850) 245 - 4640 Telephone (850) 245 ~ 4683 Facsimile PCP: H fo be PCP Members: M.K. Habgeod, B. Kemp /CS DOH v. Corleen Miller, L.P.N. 3 Case No. 2008-13857 J:\PSU\Nursing\Carla Schell\AC\Unprofessional Conduct\Miller RN (stealing from pt).doc Aug 19 2009 13:18 AUIG-19-2889 14:81 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. DOH v. Coreen Miller, LP.N. 4 Case No. 2008-13857 J.\PSU\Nursing\Carla Schell\AC\Unprofessional Conduct\Miller RN (stealing from pt).doc

Docket for Case No: 09-004570PL