STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, Ve | CASE NO. 2014-09689 IRWIN JAY BLUM, 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, Irwin Jay Blum, L.P.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. 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 5183298. _ 3. Respondent's address of record is 1723 West Patterson Street, Tampa, Florida 33604. 4, The Texas Board of Nursing is the licensing authority for nurses in the state of Texas. 5. Onor about June 10, 2014, the Board of Nursing of the State of Texas filed a default order, which revoked Respondent's license. 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 ‘anther state, territory, or county, constitutes grounds for disciplinary -action. 7. . As set forth above, on or about June 10, 2014, Respondent’s . license to practice nursing in the state of Texas was revoked by the Texas Board of Nursing, which is the licensing authority for nurses in the state of Texas, 8. Based on the foregoing, Respondent violated Section 464.018(1)(b), Florida Statutes (2013), 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. Department of Health v. Irwin Jay Blum, L.P.N. . 2 Case Number 2014-09689 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 renriinand, 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. SIGNED this _21™ day of __\\\uvch 2015. John H. Armstrong, MD, FACS ro. State Surgeon General and Secretary of Health le L. Jordan Assistant General Counsel Florida Bar Number 106034 DOH Prosecution Services Unit FILED 4052 Bald Cypress Way, Bin C-65 CEPA EN CLERK Tallahassee, Florida 32399-3265 CLERK TDS Telephone (850) 245 - 4444 Ext. 8125 Facsimile (850) 245 - 4683 nicole.jordan@flhealth.gov /NU pcp: 3(24\1S PCP Members: Heogoos wWMikKon Department of Health v. Irwin Jay Blum, L.P.N. é 3 Case Number 2014-09689 z 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. Irwin in Jay Blum, L.P.N. = 4 Case Number 2014-09689

Docket for Case No: 15-003567PL