STATE OF FLORIDA DEPARTMENT OF.HEALTH DEPARTMENT OF HEALTH, PETITIONER, Vv. CASE NO. 2012-04567 ALBERT RUSSELL WALLS, 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, Albert Russell Walls, 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 Compiaint, Respondent was a licensed practical nurse (L.P.N.) within the state of Florida, having been issued license number PN 1317131, 3. Respondent's address of record is 4410 Berra Drive #306, Wesley Chapel, Floricia 33545. 4. On or about August 30, 2011, the Baard of Nursing filed a Final Order in case number 2009-24801. 5. The Final Order suspended Respondent's license numbered PN 1317131 “until he undergoes an evaluation coordinated by the Intervention Project for Nurses (IPN), and complies with any and all terms and conditions imposed by IPN as a result of said evaluation.” 6. Respondent failed to undergo an evaluation coordinated by IPN, as required by the Final Order. 7. At all times material to — this Administrative Complaint, Respondent was employed by Arbor Meclical Staffing, located in Palm Coast, Florida as a contract licensed practical nurse 8. From on or about August 31, 2011 through on or about February 28, 2012, Respondent provided nursing services for Arbor Medical Staffing while his license was: suspended. 9. At all times material to this Administrative Compiaint, Respondent was employed by NurseStaffing, located in Ocala, Florida as a contract licensed practical nurse. Department of Health v. Albert Russell Walis, L.P.N. Case Number 2012-04567 AC — VFO, suspended license ie] 10. From on or about February 9, 2012 through on or about March 14, 2012, Respondent provided nursing services for NurseStaffing while his license was suspended. il. Section 464.018(1)(0), Florida Statutes (2011), provides that violating any provision of chapter 464 or chapter 456, or any rules adopted pursuant thereto constitutes grounds for disciplinary action. 12. Section 464.016(1)(b), Florida Statutes (2011), provides that using or attempting to use a license or certificate which has been suspended or revoked constitutes a felony of the third degree, punishable as provided in s. 775.082, s. 775.083, or s. 775.084. 13. Respondent used his license which had been suspended in one or more of the following ways: a. By providing nursing services for Arbor Medical Staffing from on or about August 31, 2011 through on or about February 28, 2012, while his license was suspended, b. By providing nursing services for ‘NurseStaffing from on or about February 9, 2012 through on or about March 14, 2012, while his license was suspended. Department of Health v. Albert Russel! Wails, L.P.N, 3 Case Number 2012-04567 AC — VFO, suspended license 14. Based on the foregoing, Respondent violated Section 464,018(1)(0), Florida Statutes (2011), by violating any provision of chapter 464 or chapter 456, or any rules adopted pursuant thereto, by violating Section 464.016(1)(b), Florida Statutes (2011), by using or attempting to use a license or certificate which has been suspended or revoked. 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. Albert Russeli Walls, L.P.N. Case Number 2012-04567 4 AC ~ VFO, suspended license SIGNED this _(it" dayof_ —s JU 2012. John H. Armstrong, MD State Surgeon General and Secretary of Health Vernisha Foster Assistant General Counsel DOH Prosecution Services Unit be FILED 4052 Bald Cypress Way, Bin C-65 SPASTMIENT OF HEALTH Tallahassee, Florida 32399-3265 GLERK Angel Sander” Florida Bar # 0092743 LS 207 Telephone: (850) 245-4640 Facsimile: (850) 245-4683 /VF 06/14/2012 BOWEN KIRKPATRICK Department of Health v, Albert Russell Walls, L.P.N. Case Number 2012-04567 AC — VFO, suspencied license ur 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 cests 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. Albert Russell Walis, L.P.N. Case Number 2012-04567 6 AC ~ VFO, Suspended license

Docket for Case No: 13-001350PL