STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, Vv. CASE NO. 2019-29565 LENORA L. STRINGFIELD, C.N.A., RESPONDENT. / ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, Department of Health (Department), by and through its undersigned counsel, and files this Administrative Complaint before the Board of Nursing against Respondent, Lenora L. Stringfield, C.N.A. and in support thereof alleges: 1. Petitioner is the state agency charged with regulating the practice of nursing assistance 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 a certified nursing assistant (C.N.A.) within the state of Florida, having been issued license number CNA 306343. 3. | Respondent's address of record is 2534 Nicholas Circle East, Jacksonville, Florida 32207. 4. Onor about March 11, 2020, in the County Court in and for Duval County, Florida, Respondent entered a plea of nolo contendere to one count of Battery, a first-degree misdemeanor violation of section 784.03(1)(a)1., Florida Statutes (2019). 5. Section 464.204(1)(b), Florida Statutes (2019), provides intentionally violating any provision of chapter 464, chapter 456, or the rules adopted by the board, constitutes grounds for disciplinary action. 6. Section 464.018(1)(d)5., Florida Statutes (2019), 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 discipline. 7. As set forth above, on or about March 11, 2020, in the County Court in and for Duval County, Florida, Respondent entered a plea of nolo contendere to one count of Battery, a first-degree misdemeanor violation of section 784.03(1)(a)1. Department of Health v. Lenora L. Stringfield, C.N.A. Case Number 2019-29565 8. Based on the foregoing, Respondent violated section 464.204(1)(b), by intentionally violating section 464.018(1)(d)5., 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. [Remainder of page intentionally left blank| Department of Health v. Lenora L. Stringfield, C.N.A. Case Number 2019-29565 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 10th day of June, 2020. Scott A. Rivkees, MD State Surgeon General FILED [s/ Logan A. White DEPARTMENT OF HEALTH Logan A. White Assistant General Counsel oLerK: (luadA Weuud Fla, Bar No. 112281 DATE: uN 9 eh Prosecution Services Unit Florida Department of Health 4052 Bald Cypress Way, Bin #C65 Tallahassee, FL. 32399-3265 Telephone: (850) 558-9913 Facsimile: (850) 245-4662 Email: logan.white@flhealth.gov PCP: 6/10/20 PCP Members: Ramos, Newman Department of Health v. Lenora L. Stringfield, C.N.A. Case Number 2019-29565 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, Lenora L. Stringfield, C.N.A. Case Number 2019-29565

Docket for Case No: 20-003819PL