STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, v. CASE NO. 2019-20485 BRIAN WILLIAM SANCHEZ, R.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, Brian William Sanchez, 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 Administrative Complaint, Respondent was a registered nurse (R.N.) within the state of Florida, having been issued license number RN 9198752. 3. Respondent’s address of record is 12 Riparian Drive, Victor, Idaho 83455. 4. Respondent may also be located at 236 Weatherstone Pointe Drive, Woodstock, Georgia 30188. 5. The California Board of Registered Nursing is the licensing authority for registered nurses in the state of California. 6. On or about May 24, 2019, the California Board of Registered Nursing entered a Decision and Order, accepting the surrender of Respondent's California nursing license. 7. The California Board of Registered Nursing’s May 24, 2019 Decision and Order constitutes action taken against Respondent's California nursing license. | | 8. Section 464.018(1)(b), Florida Statutes (2018), 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. 9. Asset forth above, Respondent had a license to practice nursing revoked, suspended, or otherwise acted against, by the licensing authority Department of Health v. Brian William Sanchez, R.N. 2 Case Number 2019-20485 of another state, territory, or country, when the California Board of Registered Nursing accepted the surrender of Respondent's license on or about May 24, 2019. 10. Based on the foregoing, Respondent violated Section 464.018(1)(b), Florida Statutes (2018). [ remainder of page intentionally left blank } Department of Health v. Brian William Sanchez, R.N. 3 Case Number 2019-20485 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 12th day of August , 2019, Scott A. Rivkees, MD State Surgeon General Ls/ Anthony Brian Coniglio ANTHONY BRIAN CONIGLIO Assistant General Counsel FILED Fla. Bar No. 1002943 DEPARTMENT OF HEALTH ’ DOH Prosecution Services Unit DEPUTY CLERK 4052 Bald Cypress Way, Bin C-65 CLERK: Bridget Contey Tallahassee, FL 32399-3265 pate: 3-\2- 20\4 Telephone: (850) 558-9870 Facsimile: (850) 245-4662 Email: anthony.coniglio@flhealth.gov PCP: August 12, 2019 PCP Members: Stone-Gale & Talmadge Department of Health v. Brian William Sanchez, R.N. - 4 Case Number 2019-20485 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 to any other discipline imposed. Department of Health v. Brian William Sanchez, R.N. 5 Case Number 2019-20485

Docket for Case No: 19-005094PL