STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, v. CASE NO. 2013-13322 CHARLES FABIO NUQUI, R.N., RESPONDENT. ADMINISTRATIVE COMPLAINT Petitioner, Department of Health, by and through its undersigned counsel, files this Administrative Complaint before the Board of Nursing against Respondent, Charles Nuqui, R.N., and in support thereof alleges: 1. Petitioner is the state agency charged with regulating the practice of nursing pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter 464, Florida Statutes (2013). 2. At all times material to this Administrative Complaint, Respondent was a licensed registered nurse (R.N.) within the state of Florida, having been issued license number RN 9341903. | ! 3. Respondent’s address of record is 398 Man O War Drive, Inverness, Florida 34453. 4. On or about August 9 2013, the California State Board of Registered Nursing issued a Decision and Order which revoked Respondent's nursing license. | ‘5. The California State Board of Registered Nursing is the licensing authority for registered nurses in the State of California. 6. Section 464.018(1)(b), Florida Statutes (2013), 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. 7. As set forth above, Respondent had a license to practice nursing revoked, suspended, or otherwise acted against when the California State Board of Registered Nursing issued a Decision and Order which revoked Respondent’s nursing license. 8. Based upon the foregoing, Respondent has violated Section 464.018(1)(b), Florida Statues (2013), 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 which constitutes grounds for disciplinary action. Department of Heaith v. Charles F. Nuqui, R.N. 2 Case Number 2013-13322 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. stGnep this _|4™ day of LlouemAes) , 20/3. John H. Armstrong, MD, FACS State Surgeon General and Secretary of Health fu on Le ’ FILED DEPARTMENT OF HEALTH Assistant General Counsel DEPUTY CLERK DOH Prosecution Services Unit CLERK Bridget Coates 4052 Bald Cypress Way, Bin C-65 pate //-2Qo-13 . Tallahassee, Florida 32399-3265 Florida Bar Number 089054 (850) 245 — 4444, ext 8228 Telephone (850) 245 - 4683 Facsimile /RCH PCP: November 19, 2013 PCP Members: Kathryn Whitson and Barbara Kemp Department of Health v. Charles F. Nuqui, R.N. , 3 Case Number 2013-13322 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. Charles F. Nuqui, R.N. . 4 Case Number 2013-13322

Docket for Case No: 14-003635PL