STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, v. _ CASE NO. 2013-01844 EMILIYA DODIN, R.N., a/k/a EMILTYA I. DODIN, a/k/a EMILY I. DODIN, a/k/a EMILY DODIN, 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, Emiliya Dodin, R.N., and in support thereof alleges: 1. Petitioner is the state department 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 9212662. 3. Respondent's address of record is 6576 Capistrano Beach Trail, Delray Beach, Florida 33446. Respondent may be located at 750 NW 30 Avenue, #A, Delray Beach, Florida 33445. Respondent may be located at 18832 Schooner Drive, Boca Raton, Florida 33946. 4. On or about June 9, 1997, a person with the initials I.K. submitted an Application for License and First Registration (New York Application) to the State Education Department, Office of the Professions, in New York, with the following identification information: social security number; date of birth; address in Kew Gardens, New York; and/or graduation from The Sverdlovsk Municipal Medical School No. 2 in Ekaterinburg, Russia, in 1987. 5. On or about January 3, 2001, I.K. was granted New York Registered Professional Nurse license number 520430 (NY — 520430). 6. Onor about September 3, 2003, I.K. renewed NY — 520430 for __ the registration period of January 1, 2004, through August 31, 2006, giving an address of East Brunswick, New Jersey. 7. On or about January 23, 2004, Respondent submitted an Application for Nursing Licensure by Endorsement (Florida Application) to the Florida Board of Nursing. Department of Health v. Emiliya Dodin, R.N. 2 Case Number 2013-01844 8. In her Florida Application, Respondent represented that she obtained NY — 520430 in 2001. 9. In her Florida Application, Respondent also submitted the following identification information: a different social security number than the one reflected on the New York Application; a date of birth thirteen years earlier than the one reflected on the New York Application; an address in Old Bridge, New Jersey; and/or graduation from nursing school in Odessa, U.S.S.R., in 1974. 10. Respondent submitted a falsified copy of a certificate of qualification to practice as a registered nurse from the University of the State of New York bearing the name “Emily I. Dodin” with her Florida Application. 11. Respondent submitted a falsified copy of an official parchment purporting to grant the license of registered professional nurse, NY — 520430, to Emily I. Dodin, dated January 3, 2001, with her Florida Application. 12. On or about February 6, 2004, Respondent obtained a license to practice registered nursing in Florida based on the above Florida Application. nt of Health v. Emiliya Dodin, R.N. 3 Case Number 2013-01844 13. Respondent renewed her Florida license on or about one or more of the following dates: February 28, 2005; February 8, 2007; January 29, 2009; and/or January 29, 2011. 14. I,K. renewed NY — 520430 on or about one or more of the following dates: September 3, 2003; April 3, 2006; April 1, 2009; April 25, 2012; and/or July 20, 2015. 15. IK. held NY — 520430 during the time period in which Respondent claimed that she held NY — 520430, as her basis for her Florida license by endorsement, during initial licensure application and subsequent license renewals. 16. I.K., now of East Brunswick, New Jersey, currently holds NY — 520430. 17. New York records do not contain any record of entry in Respondent's name as having received a license to practice Registered Professional Nursing from the New York State Education Department. COUNT ONE 18. Petitioner realleges and incorporates paragraphs one (1) through seventeen (17), as if fully set forth herein. Department of Health v. Emitiya Dodin, R.N, 4 Case Number 2013-01844 19. Section 464.018(1)(a), Florida Statutes (2003), provides that procuring, attempting to procure, or renewing a license to practice nursing by bribery, by knowing misrepresentations, or through an error of the department or the board, constitutes grounds for disciplinary action. 20. As set forth above, Respondent procured a license to practice nursing by knowing misrepresentation when she misrepresented that she had obtained and currently held NY — 520430 on her Florida Application, knowing that she did not hold NY — 520430, during the time period in which IK. held NY — 520430. 21. As set forth above, Respondent renewed her license to practice nursing by knowing misrepresentation when she renewed her Florida license, which she fraudulently obtained based on a falsified New York license, knowing that she did not hold NY — 520430, during the time period in which LK. held NY — 520430. 22. Based on the foregoing, Respondent violated Section 464.018(1)(a), Florida Statutes (2003), procuring, attempting to procure, or renewing a license to practice nursing by bribery, by knowing misrepresentations, or through an error of the department or the board. Department of Health v. Emiliya Dodin, R.N. 5 Case Number 2013-01844 COUNT TWO 23. Petitioner realleges and incorporates paragraphs one (1) through seventeen (17), as if fully set forth herein. 24. Section 456.072(1)(v), Florida Statutes (2003), provides that failing to comply with the requirements for profiling and credentialing, including, but not limited to, failing to provide initial information, failing to timely provide updated information, or making misleading, untrue, deceptive, or fraudulent representations on a profile, credentialing, or initial or renewal licensure application, constitutes grounds for disciplinary action. 25. As set forth above, Respondent failed to comply with the requirements for profiling and credentialing in one or more of the following ways: a. When she made misleading, untrue, deceptive, and/or fraudulent representations that she was properly licensed in New York, when she was not, on her initial Florida Application; b. When she submitted falsified documentation to the Board with her initial Florida Application; and/or Department of Health v. Emiliya Dodin, R.N. 6 Case Number 2013-01844 c. When she made misleading, untrue, deceptive, and/or fraudulent representations on her Florida license renewals, which were based on a fraudulently-obtained license. 26. Based on the foregoing, Respondent violated Section 456.072(1)(v), Florida Statutes (2003), by failing to comply with the requirements for profiling and credentialing, including, but not limited to, failing to provide initial information, failing to timely provide updated information, or making misleading, untrue, deceptive, or fraudulent representations on a profile, credentialing, or initial or renewal licensure application. 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.] Department of Health v. Emiliya Dodin, 8.N. 7 Case Number 2013-01844 st SIGNED this | “—~_ day of J Dectmpel , 2015. D OF HEA’ DEPUTY CLERK ‘TH CLERK _DATE pare “BEES PT sre FIL DEPARTMENT: JALP pep: 2) 1 John H. Armstrong, MD, FACS State Surgeon General and Secretary of Health S, Ann L. Prescott Assistant General Counsel DOH Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, Florida 32399-3265 Florida Bar Number 0092974 (850) 245 — 4444 Telephone (850) 245 — 4662 Facsimile Email: Ann.Prescott@flhealth.gov PCP Members: Colin* bhava Department of Health v. Emiliya Dodin, R.N. Case Number 2013-01844 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. Emiliya Dodin, R.N. 9 Case Number 2013-01844

Docket for Case No: 21-000075PL