STATE OF FLORIDA DEPARTMENT OF HEALTH _DEPARTMENT OF HEALTH, PETITIONER, v. : CASE NO. 2018-05045 JACQUELYN M. EREMITA, 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, Jacquelyn M. Eremita, 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 9446925. 3. | Respondent's address of record is 2852 Tanglewood Drive, Orange Park, Florida 32065. | 4. On or about July 16, 2018, in the Circuit Court of the Ninth Judicial Circuit, in and for Osceola County, Florida, Respondent entered pleas of nolo contendere to two counts of Battery, a first-degree misdemeanor in violation of Section 784.03(1)(a)(2), Florida Statutes (2018), and.one count of Resisting an Officer without Violence, a first-degree misdemeanor in violation of Section 843.02, Florida Statutes (2018). | 5. Respondent failed to report to the Board, in writing, within thirty days of entering the aforementioned pleas. COUNT I 6. Petitioner realleges and incorporates paragraphs one (1) through five (5) as if fully set forth herein. 7. Section 464.018(1)(d)(5), Florida Statutes (2018), provides that being convicted or found guilty of, or entering a plea of guilty or nolo contendere to, regardless of adjudication, a violation of Chapter 784, relating to assault, battery, and culpable negligence constitutes grounds for disciplinary action. 8. Asset forth above, on or about July 16, 2018, in the Circuit Court of the Ninth Judicial Circuit, in and for Osceola County, Florida, Respondent entered pleas of nolo contendere to two counts of Battery, a first-degree misdemeanor in violation of Section 784.03(1)(a)(2), Florida Statutes (2018). | 9. Based on the foregoing, Respondent violated Section 464.018(1)(d)(5), Florida Statutes (2018), by being convicted or found guilty of, or entering a plea of guilty or nolo contendere to, regardless of adjudication, a violation of Chapter 784, relating to assault, battery, and culpable negligence. . COUNT II 10. Petitioner realleges and incorporates paragraphs one (1) through five (5) as if fully set forth herein. 11. Section 456.072(1)(x), Florida Statutes (2018), provides that failing to report to the board, or the department if there is no board, in writing within 30 days after the licensee has been convicted or found guilty of, or entered a plea of nolo contendere to, regardless of adjudication, a crime in any jurisdiction constitutes grounds for disciplinary action. 12. As set forth above, Respondent failed to report entering pleas of nolo contendere to the crimes of Battery and Resisting an Officer without Violence to the Board of Nursing in writing within thirty days after Respondent entered the pleas. . 13. Based on the foregoing, Respondent violated Section 456.072(1)(x), Florida Statutes (2018), by failing to report to the board, or the department if there is no board, in writing within 30 days after the ~ ficensee has been convicted or found guilty of, or entered a plea of nolo contendere to, regardless of adjudication, a crime in any jurisdiction. 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. [signature page follows| SIGNED this__23__ day of ___ April , 2019. FILED lal Phil A. DEPARTMENT OF HEALTH — DEPUTY CLERK Philip A. Crawford CLERK: 0 yr Maus Assistant General Counsel DOH Prosecution Services Unit »___APR 2 4 2019 i pate: _APR 4052 Bald Cypress Way, Bin C-65 Tallahassee, Florida 32399-3265 Florida Bar Number 91378 (850) 558-9829 Telephone (850) 245-4662 Facsimile Email: Philip.Crawford@flhealth.gov’ /PAC PCP: April 23, 2019 PCP Members: McDonough & Glymph 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.

Docket for Case No: 19-005184PL