XAV IER BECERRA

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Attorney Genera l of Ca lifo rnia
CHAR SACHSON
Supervising Deputy Attorney General
L ESLIE E. BRAST
Deputy Attorney General
State Bar No. 203296
455 Go lden Gate Avenue, Suite 11000 

San Francisco, CA 94 I02-7004 

Te lephone: (415) 510-3373 

Facs imile: (415) 703-5480 

Attorneysfor Complainant

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BEFORE THE 

BOARD OF REGISTERED NURSING 

DEPARTMENT OF CONSUMER AFFAIRS 

STATE OF CALIFORNIA 


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In the Matter of the Accusation Against:

Case No.

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NALINEE PIMPHAN
2803 W. Bluff Ave.
Fresno, CA 93711

FIRST AMENDED ACCUSATION

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Registered Nurse License No. 522582
Nurse Practitioner Certificate No. 12678
Nurse Practitioner Fu rnishing No. 12678
Public Health Nurse Certificate No. 57926

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Responde nt.
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Complainant a lleges: 


PARTIES 


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l.

Joseph L. Morris, PhD, MSN, RN (Compla inant) brings this Accusation so le ly in his

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offi cia l capacity as the Executive Officer of the Board of Registered N ursing (Board),

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Department of Consume r Affairs.

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2.

O n or about June I 4, 1996, the Board issued Registered Nurse License N um ber

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522582 to Nalinee Pimpha n (Respondent). T he Reg istered Nurse License was in fu ll force and

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effect at all times relevant to the charges brought here in and wil l exp ire on September 30, 20 I9,

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un less renewed.

FIR ST AMENDED ACCUSATION

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On or about July 30,2001, the Board issued Nurse Practitioner Certificate Number

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12678 to Respondent. The Nurse Practitioner Certificate was in full force and effect at all times

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relevant to the charges brought herein and wiJI expire on September 30, 2019, unless renewed.
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On or about August 28, 1997, the Board issued Public Health Nurse Certificate

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Number 57926 to Respondent. The Public Health Nurse Certificate was in full force and effect at

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all times relevant to the charges brought herein and wiJI expire on September 30, 2019, unless

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renewed.
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On or about October 20, 2006, the Board issued Nurse Practitioner Furnishing

Certificate number 12678 to Respondent. The Nurse Practitioner Furnishing Certificate was in

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full force and effect at all times relevant to the charges brought herein and will expire on

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September 30, 2019, unless renewed.

JURISDICTION

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6.

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This Accusation is brought before the Board under the authority of the following

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laws. All section references are to the Business and Professions Code (Code) unless otherwise

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indicated.

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Code section 2750 provides, in pertinent part, that the Board may discipline any

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licensee, including a licensee holding a temporary or an inactive license, for any reason provided

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in Article 3 (commencing with section 2750) of the Nursing Practice Act.
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Code section 2764 provides, in pertinent part, that the expiration of a license shall not

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deprive the Board of jurisdiction to proceed with a disciplinary proceeding against the licensee or

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to render a decision imposing discipline on the license.

STATUTORY AND REGULATORY PROVISIONS

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The board may take disciplinary action against a certified or licensed nurse or deny an

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Code section 2761 states, in pertinent part:

application for a certificate or license for any of the following:
(a) Unprofessional conduct ....

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Ill
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FIRST AMENDED ACCUSATION

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COSTS

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Code section 125.3 provides, in pertinent part, that the Board may request the

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administrative law judge to direct a licentiate found to have committed a violation or violations of

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the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

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enforcement of the case.

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CAUSE FOR DISCIPLINE

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(Unprofessional Conduct)

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II.

Respondent is subject to disciplinary action under Code section 2761(a) for

unprofessional conduct, as follows:
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On numerous occasions in 2012, Respondent, who worked as a nurse practitioner

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under the supervision of a physician in Fresno, California, prescribed hydrocodone for a

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psychiatric patient under Respondent's care. In doing so, Respondent failed to conduct and

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document in the patient's medical record an adequate assessment justifying the prescription of

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narcotics for the patient.

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PRAYER

WHEREFORE, Complainant requests that a hearing be held on the matters herein alleged,
and that following the hearing, the Board of Registered Nursing issue a decision:
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Revoking or suspending Registered Nurse License Number 522582, issued to Nalinee

Pimphan (Respondent);
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Revoking or suspending Nurse Practitioner Certificate Number 12678, issued to

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Respondent;

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3.

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Respondent;

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4.

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Revoking or suspending Public Health Nurse Certificate Number 57926, issued to

Revoking or suspending Nurse Practitioner Furnishing Certificate Number 12678,

issued to Respondent;
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Ordering Respondent to pay the Board of Registered Nursing the reasonable costs of

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the investigation and enforcement of this case, pursuant to Business and Professions Code section

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125.3; and,
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FIRST AMENDED ACCUSATION

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Taking such other and further action as deemed necessary and proper.

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DATED :

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1\pri I 25,

2010

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sr-. -;-M=o=RRI==s,-;P=HD~,--;-M-;:s=N-;-,--;::R=N,------1   Execut ive Officer

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Board ofRegistered N ursing
Departme nt of Consumer Affairs
State of Ca lifo rnia

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Complainant

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SF201820 1034 

21396090.docx 


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FIRST AMENDED ACCUSAT lON