STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, v. CASE NO. 2020-37737 AMANDA KAY DEARMAN, 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, Amanda Kay Dearman, 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 9551352, 3. Respondent's address of record is 10263 Allamanda Circle, Palm Beach Gardens, Florida 33410. 4, Respondent may be found at 19411 E. 37th Street South, Broken Arrow, Oklahoma 74014; 530 Quigley Hill Road, Adrian, Pennsylvania 16210; or 6614 W. Indiantown Road, Suite 500, Jupiter, Florida 33458. 5. In or about January of 2016, Respondent held Oklahoma registered nursing license number RO106339. 6. On or about January 26, 2016, the Oklahoma Board of Nursing accepted Stipulations, Settlement and Order, severely reprimanding Respondent's license and requiring her to complete continuing education courses and to pay an administrative penalty in the amount of $1,000.00. 7. Onor about November 23, 2020, Respondent submitted a Florida Registered Nurse Application and answered “no” to the question, “Have you ever had disciplinary action taken against your license to practice any health care related profession by the licensing authority in Florida or in any other state, jurisdiction or country?” 8. Section 464.018(1)(a), Florida Statutes (2020), provides that procuring, attempting to procure, or renewing a license to practice nursing or the authority to practice practical or professional nursing pursuant to Department of Health v. Amanda Kay Dearman, R.N. Case Number 2020-37737 ° section 464.0095 by bribery, by knowing misrepresentations, or through an error of the department or the board, constitutes grounds for disciplinary action. 9. Asset forth above, on or about November 23, 2020, Respondent made a knowing misrepresentation on her Florida registered nurse application when she answered “no” to the question referenced in paragraph seven. 10. Based on the foregoing, Respondent violated section 464.018(1)(a), by procuring, attempting to procure, or renewing a license to practice nursing or the authority to practice practical or professional nursing pursuant to section 464.0095 by bribery, by knowing misrepresentations, or through an error of the department or the board. [Remainder of page intentionally left blank] Department of Health v, Amanda Kay Dearman, R.N. Case Number 2020-37737 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 15th day of February , 2021. Scott A. Rivkees, MD State Surgeon General DEPARTMENT OF HEALTH [sf Judson Searcy DEPUTY CLERK JUDSON SEARCY CLERK: J Assistant General Counsel DATE: FEB 1 5 2021 Fla. Bar No. 98772 Florida Department of Health Prosecution Services Unit 4052 Bald Cypress Way, Bin #C65 Tallahassee, FL 32399-3265 Telephone: (850) 558-9898 Facsimile: (850) 245-4662 Email: judson.searcy@flhealth.gov PCP: 02/12/2021 PCP Members: Munoz & Paschall Department of Health v. Amanda Kay Dearman, R.N. Case Number 2020-37737 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. Amanda Kay Dearman, R.N. Case Number 2020-37737

Docket for Case No: 21-001447PL