STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, v. | CASE NO. 2015-01991 LINDA ROSE ENNIS HUNT, 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, Linda Rose Ennis Hunt, 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 PN353111. 3. Respondent's address of record is 1213 Northeast 31* Avenue, Gainesville, Florida 32609. 4, At all times material to this Administrative Complaint, Respondent was employed as an L.P.N. at North Florida Rehabilitation and Specialty Care, (‘North Florida Rehab”), a nursing home located in Gainesville, Florida. . 5. . At all times material to this Administrative Complaint, R.W. was ' a 68 year old male patient at North Florida Rehab with diagnoses of dementia, diabetes, and physical limitations and infirmities of aging. 6. Respondent represented to R.W. that she was experiencing financial problems. 7. Onor about November 6, 2014, R.W. wrote check number 8550 for $250.00 to J.H., Respondent's daughter. | 8. On or about November 7, 2014, R.W. wrote check number 8551 for $350.00 to J.H. 9. Section 456.072(1)(n), Florida Statutes (2014), provides that exercising influence on the patient or client for the purpose of financial gain of the licensee or a third party constitutes grounds for disciplinary action. DOH v. Linda Rose Ennis Hunt, L.P.N, 2 DOH Case No. 2015-01991 10. Respondent exercised influence on patient R.W. for the purpose of financial gain of Respondent's daughter, J.H., by influencing R.W. to ~ write two checks to J.H. totaling $600.00. 11. Based on the foregoing, Respondent has violated Section 456.072(1)(n), Florida Statutes (2014). [ remainder of page intentionally left blank | DOH v. Linda Rose Ennis Hunt, L.P.N, : 3 DOH Case No. 2015-01991 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, | SIGNED this_*" day of June 2015. John H. Armstrong, MD, FACS State Surgeon General and Secretary of Health CHRISTOPHER A. JURI 7 Assistant General Counsel Fla. Bar No, 0099014 DOH Prosecution Services Unit FILED 4052 Bald Cypress Way, Bin C-65 H CEPA MUTY CLERK Tallahassee, FL 32399-3265 cLERK Cngel Sanders Telephone: (850) 245-4444 ext. 8174 DATE JUN 0.9 2018.. ~~ Facsimile: (850) 245-4662 Email: christopher.jurich@fihealth.gov /CAJ PCP Meeting: June 8, 2015 PCP Members: Lavigne Kirkpatrick, Deborah McKeen DOH v. Linda Rose Ennis Hunt, L.P.N, : . 4 DOH Case No, 2015-01991 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. Linda Rose Ennis Hunt, L.P.N. 5 DOH Case No. 2015-01991

Docket for Case No: 15-006205PL