Verified Complaint

Comes the Plantiff, Kentucky Board of Nursing, by counsel, and for its complaint states the following:

1. The Plantiff, Kentucky Board of Nursing, is the duly constitued authority for the regulation and control of the practice of nursing in the state pursuant to KRS Chapter 314.

2. The Defendant, Mary Ann Watson, resides in the city of Paris, Bourbon County, Commonwealth of Kentucky, and hold herself out to the public as being engaged in the profession of providing antepartum, intrapartum, postpartum and neonatal services to women and newborns.

3. Such acts of Defendant consitite the practice of Nursing, specifically the practice of an advanced registered nurse practioner, designated nurse midwife, as defined in KRS 314.011(7) and (8) and KRS 314.042.

4. Defendant has never obtained a license/registration as a registered nurse/advanced registered nurse pratcioner, desginated nurse midwife to practice in Kentucky as required by KRS CHapter 314 and therefore is without right to practice nursing in this state, pursuant to KRS 314.031(1).

5. Under the terms of KRS 314.991(1) and (11), Plantiff board is entitled to the issuance of a permanent injunction by this Court forbidding and enjoining Defendant from practicing nursing in Kentucky until she obtains the license/registration required by statue.

Wherefore, the Kentucky Board of Nursing demands:

1. That this Court enter an Order declaring Defendant to be practicing nursing in violation of the laws of the Commonwealth of Kentucky;

2. That a permanent injunction be issued enjoining Defendant directly or indirectly from, in any manner, practicing nursing in Kentucky until the license required by KRS Chapter 314 is obtained; and

3. That Plantiff be granted costs in this proceeding and be granted any and all other relief to which it may be entitled.