STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, v. CASE NO. 2011-02590 ROSE G. VASSOR, 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, Rose G. Vassor, 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 Administrative Complaint, Respondent was a licensed practical nurse (L.P.N.) within the state of Florida, having been issued license number PN 5159269. Filed July 10, 2012 2:34 PM Division of Administrative Hearings 3. Respondent's address of record is 16275 NE 19 CT, Apt. 3, North Miami Beach, Florida 33162. 4. The New York State Education Department is the licensing authority for nurses in the State of New York. 5. Respondent's New York nursing license is license number 184151. 6. On or about March 21, 2006, the New York State Education Department voted on and approved an Order which suspended Respondent’s New York nursing license for a period of twenty-four months, with the last twelve months of the suspension stayed, and a fine of $2500. 7. Section 464.018(1)(b), Florida Statutes (2005), provides that having a license to practice nursing revoked, suspended, or otherwise acted against, including the denial of licensure, by the licensing authority of another state, territory, or country constitutes grounds for disciplinary action. 8. Respondent had a license to practice nursing revoked, suspended, or otherwise acted against, including the denial of licensure, by the licensing authority of another state, territory, or country, when on or about March 21, 2006, the New York State Education Department voted on Department of Health v. Rose G. Vassor, L.P.N, 2 Case Number 2011-02590 J:\PSU\Nursing\Jodi-Ann Johnson\Administrative Complaints\Out of State Violations\Vassor, Rose (LPN, OOS).doc and approved an Order which suspended Respondent's New York nursing license for a period of twenty-four months, with the last twelve months of the suspension stayed, and imposed a fine of $2500. 9. Based on the foregoing, Respondent violated Section 464.018(1)(b), Florida Statutes (2005), by having a license to practice nursing revoked, suspended, or otherwise acted against, including the denial of licensure, by the licensing authority of another state, territory, or country. 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. Department of Health v. Rose G. Vassor, L.P.N. 3 Case Number 2011-02590 J:\PSU\Nursing\Jodi-Ann Johnson\Administrative Complaints\Out of State Violations\Vassor, Rose (LPN, OOS).doc SIGNED this wud FILE! DEPARTMENT OF HEALTH DEPUTY CLERK CLERK Angel Sanders pate SEP 15 201 /3N3 09/13/2011 P. DITTMAN L. KIRKPATRICK \2 day of SC jkemblr, 2011. H. Frank Farmer, Jr., MD, PhD, FACP State Surgeon General | : NY Aon ¥ di-Ann V. Johnson sistant General\Counsel DOH Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, Florida 32399-3265 Florida Bar Number 0073525 (850) 245 - 4640 Telephone (850) 245 - 4683 Facsimile Department of Health v. Rose G. Vassor, L.P.N. Case Number 2011-02590 J:\PSU\Nursing\Jodi-Ann Johnson\Administrative Compiaints\Out of State Violations\Vassor, Rose (LPN, O0S).doc 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. Rose G. Vassor, L.P.N. 5 Case Number 2011-02590 J:\PSU\Nursing\Jodi-Ann Johnson\Administrative Complaints\Out of State Violations\Vassor, Rose (LPN, O0S).doc

Docket for Case No: 12-002328PL