. therapist having been issued license number MA 0012567. STATE OF FLORIDA DEPARTMENT OF HEALTH BOARD OF MASSAGE THERAPY DEPARTMENT OF HEALTH, PETITIONER, vs. CASE NUMBER: 2000-12446 YALCIN GURESEN, L.M.T. 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 (hereinafter the “Board”) against Yalcin Guresen, L.M.T., (hereinafter referred to as “Respondent”) and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of massage pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes (formerly Chapter 455, Part U5, see Chapter 2000- 160, Laws of Fesids), 8 and nd Chapter 4 480, Florida Statutes. Pursuant to the 3 autho of Section 20.43 appropriate. 2. . Respondent is and was at all times material hereto a li ee mere pee ve ae ae 3. Respondent’s last known address is 2780 South Oakland Forest Drive, #1406, Ft. Lauderdale, Florida 33309. . 4. On or about August 28, 2000, Respondent performed massage therapy on Patient K.V. at Patient K.V.’s home (the “Massage Session”). 5. During the Massage Session, Respondent engaged in, among other misconduct, the following sexual activity: (a) touching Patient K.V.’s genitals; (b) massaging Patient K.V.’s buttocks and penetrating her anus with his fingers; (c) touching Patient K.V.’s breasts and nipples; and (d) kissing Patient K.V.’s left nipple. 6. Based on the foregoing, Respondent violated Section 480.046(1)(k), Florida Statutes, by violating the following: (a) Section 480.0485, Florida Statutes, by using the massage therapist-patient relationship to induce or attempt to induce the patient to engage, or to engage or attempt to engage the Patient, in sexual activity; (b) Rules 64B7- 26. 010( 1) and (3), Florida Administrative Code, by engaging in sexual activity in a massage establishment and by using the therapist-client relationship to engage in sexual activity with a client and/or by making arrangements to engage in sexual activity with a client. "WHEREFORE, Petitioner respect requests the Board to enter an order ; imposing one or more of the following penalties: “revocation or suspension of the Respondent's license, restriction of the Respondent’s practice, imposition of an administrative fine, i issuance of a reprimand; placement of the Respondent on probation, assess s costs off investigation and prosecution andlor any other relief that the Board ‘deems appropriate.