STATE OF FLORIDA DEPARTMENT OF HEALTH SS HAFOR py 34 EM, 4% DEPARTMENT OF HEALTH, “Ugo: “by . : : “Coreg, Petitioner, . ; . . . Fe v. . CASE NO.: 97-08259 GARY J. SANTUCCI, 00 C20 Respondent. / ADMINISTRATIVE COMPLAINT DEPARTMENT OF HEALTH, hereinafter referred to as “Petitioner”, files this Administrative Complaint before the Board of Clinical Social Work, Marriage and Family Therapy, and Mental Health Counseling against GARY J. SANTUCCI, hereinafter referred to as “Respondent”, and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of Mental Health Counseling pursuant to Section 20.43, Florida Statutes, Chapter 455, Florida Statutes, and Chapter 491, Florida Statutes. Pursuant to the authority of Section 20.43(3)(g), 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, including the issuance of emergency orders of suspension or restriction. 2. Respondent is, and has been at all times material hereto, a licensed Marriage and Family Therapist in the state of Florida, having been issued license number MT 0000682. EXHIBIT 1 A UY WY 3. Respondent’s last known address is 3501 South University Drive Suite #10, Ft. Lauderdale, Florida 33328. 4, Ina letier to the American Board of Physical Medicine and Rehabilitation (ABPMR) dated February 11, 1997, Respondent held himself out as being a Licensed Psychotherapist. 5. Under his marriage and family therapist license, Respondent can refer to his services as “psychotherapy”. However, Respondent cannot use the title “Licensed Psychotherapist”, as there is no such licensure in Florida. COUNT I 6. Based on the foregoing, Respondent has violated Section 491.009(2)(1), Florida Statutes, by making misleading, deceptive, untrue, or fraudulent representations in the practice of any profession licensed, registered, or certified under this chapter. WHEREFORE, Petitioner respectfully requests the Board of Clinical Social Work, Marriage and Family Therapy, and Mental Health Counseling to enter an order imposing one or more of the following penalties: revocation or suspension of Respondent’s license, restriction of Respondent’s practice, imposition of an administrative fine, issuance of a reprimand, placement of 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. . Nw) VY Signed this = (Shaay of ., 1999. Robert G. Brooks, M.D. Nad¢y M. Snurko Chief Attomey ' General Counsel’s Office-MQA Allied Health 2 COUNSEL FOR PETITIONER Susan Branson, Staff Attorney Fla. Bar. No. 0648809 Agency for Health Care Administration P.O. Box 14229 Tallahassee, FL 32317-4229 Phone: (850) 487-9694 Secretary Department of Health FILED SB DEPARTMENT OF HEALTH EPUTY CLERK PCP: March 25, 1999 CLERK Priphesus 0, ew DATE A: “AG. S&

Docket for Case No: 00-000620