ae mony £ Q STATE OF FLORIDA hah DEPARTMENT OF HEALTH 00 JAN 25 PM 3:32 DEPARTMENT OF HEALTH, _ OWE oy oF Petitioner, vs. CASE NO.: 98-00724 JON EDWARD MUNDORFF, (O-04 1 D Respondent. . oe ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as “Petitioner,” and files this Administrative Complaint before the Board of Psychology, and against Jon Edward Mundorff, hereinafter referred to as “Respondent” alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of Psychology pursuant to Section 20.43, Florida Statutes (Supp. 1996); Chapter 455, Florida Statutes, Chapter 490, Florida Statutes. Pursuant to the authority of Section 20.43(3)(g), Florida Statute, the Petitioner has contracted with the Agency for Health Care Administration 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 has been at all times material hereto, a licensed Psychologist in the state of Florida, having been issued license number 0002471. 3. Respondent’s last known address is 3105 West El Prado Boulevard, Tampa, FL 33629-8946. 4, The patient, C.R.A., received therapy for phobias from Respondent from 1980 to 1990. | 5. During this time, patient and Respondent became friends and frequently traveled together. Respondent attempted to entice C.R.A. to become sexually involved with him. Respondent violated the boundaries of the patient-therapist relationship. 6. On or about August 1997, C.R.A. contacted the Respondent and made an appointment to obtain his therapy/medical records. On August 10, 1997, C.R.A. traveled to the Respondent’s office to retrieve his records. The Respondent refused to give C.R.A. the records. 7. On or about August 10, 1997, Respondent asked C.R.A. for one of his prescriptions, Restoril, so that he could dispense the medication to one of his patients who could not afford it. 8. On or about August 10, 1997, Respondent indicated to C.R.A. that he should stop seeing his current physician. At this time, Respondent also told C.R.A. to stop taking the prescription, Nardil, which his current physician had prescribed, for him. In addition, Respondent requested that C.R.A. return to him for therapy and pays a fee of ten percent of C.R.A.’s salary. COUNTI 16. _ Petitioner realleges and incorporates by reference the allegations contained in paragraphs one (1) through nine (9) as if fully stated within. 17. Based on the foregoing, the Respondent has violated Section 490.009 (2)(s), Florida Statutes, by failing to meet the minimum standards of performance in professional activities when measure against generally prevailing peer performance, including the undertaking of activities for which the licensee is not qualified by training or experience by entering into a dual relationship with C.R.A. WHEREFORE, Petitioner respectfully requests the Board of Psychology 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, issuance of a reprimand, placement of the Respondent’s license on probation for a period of time and subject to terms and/or conditions, and /or any other relief which the Board deems appropriate. Signed this SMa aay of | baleonlon , 1998 Douglas M. Cook itector. By: © Nancy M. Snurkowski : Chief Attorney ri LE D On Behalf of the Agency for DEPARTMENT OF HEALTH Health Care Administration EPUTY CLERK | cxsnegptiphane 0, te DATE_ 10-3S-TE U Y (COUNSEL FOR PETITIONER: ‘Walter Flinn, Attorney Florida Bar No.: 0015921 Agency For Health Care Administration ?.O. Box 14229 Tallahassee, Florida 32317-4229 ‘Phone 850/ 487-3908 Fax 850/414-1991 PCP. “Frank ; Civas- Vareper ; Levsis PLP Doe! September 10, 14a

Docket for Case No: 00-000413