U U STATE OF FLORIDA DEPARTMENT OF HEALTH BOARD OF MASSAGE THERAPY DEPARTMENT OF HEALTH, PETITIONER, vs. CASE NUMBER: 99-01598 WENDY ANNE WILSON, OO - G 73 RESPONDENT. / ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as “Petitioner,” and files this Administrative Complaint before the Board of Massage Therapy against WENDY ANNE WILSON, hereinafter referred to as “Respondent,” and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of massage therapy pursuant to Section 20.43, Florida Statutes; Chapter 455, Florida Statutes; and Chapter 480, Florida Statutes. Pursuant to the authority of Section 20.43 (3)(g), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration, hereinafter “Agency,” to provide consumer complaint, investigative, and prosecutorial services required by the Division of Medical Quality Assurance, councils, or boards, as appropriate. 2. Respondent is, and at all times material hereto, a duly licensed massage therapist having been issued license number MA 0015106. Also Respondent is the WU Ld Owner of a duly licensed massage establishment having been issued license number MM- 1008. oe 3. Respondent’s last known address is 1008 Moccasin Run Road, Oviedo, Florida 32765. 4, On or between September 15, 1998 and February 5, 1999, the Metropolitan Bureau of Investigation (hereinafter referred to as MBI) Vice Unit conducted an undercover investigation at DREAMSTATE in response an anonymous complaint reporting sexual activity at the establishment. 5. Respondent admitted to performing sex for money; “...hand jobs only...one client I see on the outside...who in the heck wouldn’t want to have sex with a man for five hundred?” 6. Respondent also admits to performing oral sex on clients. 7. Respondent admits to hiring unlicensed massage therapists to practice at her establishment. 8. Respondent admits to sending her employed unlicensed therapists on “outcalls” for the purpose of prostitution. 9. Of the four massage rooms in the establishment, semen samples were collected from all four rooms. 10. Onor about February 5, 1999, MBI closed down the Respondent’s massage establishment. COUNT I 11. Petitioner repeats and realleges the allegations of paragraphs 1 ~ 10 above. U Ud 12. Based on the foregoing, Respondent engaged in sexual activities for money and is subject to discipline pursuant to Section 480.0485, 480.046 (1)(k) Flerida Statutes, for inducing or attempting to induce the patient to engage, or attempting to engage the patient, in sexual activity outside the scope of practice or the scopé of generally accepted examination or treatment of the patient. | COUNT II 13. Petitioner repeats and realleges the allegations of Paragraphs 1 — 10 above. 14, Based on the foregoing, sexual activity took place in the Respondent’s establishment and arrangements for further sexual activity were made there, making Respondent subject to discipline pursuant to Section 480.046(1)(k), Florida Statutes, for violating Rule 64B7-26.010, Florida Administrative Code, absolutely prohibiting sexual activity in the practice of massage therapy. COUNT Wil 15. Petitioner repeats and realleges the allegations of paragraphs 1 — 10 above. 16. Based on the foregoing, Respondent hired unlicensed massage therapists and advised them to practice contrary to the provisions of this chapter and is subject to discipline pursuant to Section 480.046(1)(e), Florida Statutes, for aiding, assisting, procuring, or advising any unlicensed person to practice massage contrary to the provisions of this chapter or to a rule of the department or board. WHEREFORE, Petitioner respectfully requests the Board of Massage Therapy ” enter an order imposing one or more of the following penalties: Revocation or suspension of the Respondent’s practice, imposition of an administrative fine, issuance of t i ator a reprimand, placement of the Respondent on probation, assess costs of investigation and prosecution and/or any other relief that the Board deems appropriate. SIGNED this | HV aay of egal 1999. Robert G. Brooks, M.D. Secretary, Department of Health ancy M. Snurkows! Chief Attorney Agency for Health Care Administration oo ACOUNSEL FOR PETITIONER: Gary L. Asbell, Senior Attorney Agency for Health Care Administration Practitioner Regulation - Legal P.O. Box 14229 Fl LED Tallahassee, Florida 32317-4229 DEPARTMENT OF HEALTH (850)410-3469 GLA/ffm PCP: DATE: aso

Docket for Case No: 00-000673