STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, Vv. - CASE NO. 2017-00588 BRYAN CHRISTOPHER HABER, R.N., RESPONDENT. / DMINISTRATIVE COMPLAINT Petitioner Department of Health (Department) files this Administrative Complaint before the Board of Nursing (Board) against Respondent Bryan Christopher Haber, 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. 2. At all times material to this Complaint, Respondent was licensed to practice nursing within the State of Florida, having been issued license number RN 9349028. 3. At all times material to this Complaint, Respondent’s address of record is 1624 Misty Lake Drive, Fleming Island, Florida 32003. ( 4. | Onor about November 7, 2016, Dr. Scott A. Teitelbaum, M.D., a physician specializing in psychiatric and addiction medicine, evaluated Respondent. 5. Dr. Teitelbaum diagnosed Respondent with Unspecified Opiate Use Disorder, Unspecified Alcohol Use Disorder, Posttraumatic Stress Disorder, and Chronic Pain. 6. Dr. Teitelbaum opined that Respondent is unable to practice nursing with reasonable skill and safety to patients. 7. Section 464,018(1)(j), Florida Statutes (2016), allows the Board of Nursing to impose discipline against a licensee for being unable to practice nursing with reasonable skill and safety to patients by reason of illness or use of alcohol, drugs, narcotics, or chemicals or any other type of material or as a result of any mental or physical condition. 8. Respondent is unable to practice nursing with reasonable skill and safety to patients by reason of one or more of the following: a. Unspecified Opiate Use Disorder; b. Unspecified Alcohol Use Disorder; c. Posttraumatic Stress Disorder; and/or d. Chronic Pain. Administrative Complaint DOH v. Bryan Christopher Haber, R.N. 2017-00588 9. Based on the foregoing, Respondent violated Section 464.018(1)(j), Florida Statutes (2016). | WHEREFORE, Petitioner respectfully requests that the Board 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 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_W' day of Marc, _, 2017. Celeste Philip, M.D., M.P.H. Surgeon General and Secretary Qusonan CNet Amy C. Thorn Assistant General Counsel FL. DOH Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, FL 32399-3265 FILED Florida Bar Number 92097 D e EPUTY Olen Sm (P) (850) 245-4444 ext. 8154 CLERK Amber Greene DATE MAR 0 7 9017 (F) (850) 245-4662 _(E) Amy. Thorn @flhealth.gov PCP: March 6, 2017 PCP Members: Rosa Ramos and Derrick C. Glymph 3 Administrative Complaint DOH v. Bryan Christopher Haber, R.N. 2017-00588 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. A request or petition for an administrative hearing must be in writing and must be received by the Department within 21 days from the day Respondent received the Administrative Complaint, pursuant to Rule 28-106.111(2), Florida Administrative Code. If Respondent fails to request a hearing within 21 days of receipt of this Administrative Complaint, Respondent waives the right to request a hearing on the facts alleged in this Administrative Complaint pursuant to Rule 28-106.111(4), Florida Administrative Code. Any request for an administrative proceeding to challenge or contest the material facts or charges contained in the Administrative Complaint must conform to Rule 28-106.2015(5), Florida Administrative Code. Mediation under Section 120.573, Florida Statutes, is not available to resolve this Administrative Complaint. 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 any other discipline imposed. Administrative Complaint DOH v. Bryan Christopher Haber, R.N. 2017-00588

Docket for Case No: 19-001527PL