Re a whe ke aie. . 20.43, Florida Statutes; Chapter we . Ww FILED. STATE OF FLORIDA RECEIVED - LEGAL 00 JUN20 BIERARSMENT OF HEALTH 00 APR 25 py 3:97 DEPARTMENTS Sire, | KE. RINGS Petitioner, vs. CASE NO.: 98-19949 00-395 34 TYRONE S. LEWIS, Respondent. . / ADMINISTRATIVE COMPLAINT / Petitioner, 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 TYRONE STEVEN LEWIS, hereinafter referred to as “Respondent, ” and alleges: “1. Effective July 1, 1997, Petitioner is the s state agency charged hapter 491, SPM oe At Mseabergasnat Sateen we Florida Statutes. - Pursuant to the authority ‘of Section 20. 43 ()(g)s Florida. "Statutes, the Petitioner has contacted with the Agency for Health Care Admin dec consumer complaint, investigative, and prosecutorial services es required byth the Division of Medical Ouality . 0002 0 2 wav Assurance, councils, or boards, as appropriate. 2. Respondent is, and has been at all times material hereto,.a licensed Mental Health Counselor in the state of Florida, having been issued license number MH 0002533. Respondent’s last known address is 10239 Boca Bend West #4, Boca Raton, Florida, 33428. 3. Patient C.S. began receiving mental health therapy from the | Respondent on or about September, 24, 1992. Her last appointment with the Respondent was on or about May 15, 1997. ; 4, Patient CS. had requested, in writing, copies of her therapeutic records from the Respondent several times prior to the date of this | “ complaint which was December 7, 1998. 5. However, the Respondent failed to provide either C.S. or AHCA investigators with copies or the requested therapeutic records until April 13, 1999. The requested records were provided to the AHCA investigator on this date. Based 0 on the foregoing, the Respondent's license to practice as a Mental Health Therapist in the State of Florida i is subject to discipline pursuant to Section 491.009(2)(n), Florida Statutes, by failing to make available to a patient or client, upon written request, copies of tests, reports, ~ ws or documents in the possession of or under the control of the licensee....; and Section 491 .009(2)(0), failing to respond within thirty (30) days to a written communication from the department. ’ 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 other relief which the Board deems appropriate. SIGNED this wy Haay of 4d vf Be Robert G. Brooks, MD. Secretary, Department of Health" DEPARTMENT OF HEALTH - os —Y 9 CLERK Wh RG; oe an Meh Kbiom o Y: Nancy M. Snurkowski, pate“ £0 - 2000 Chief Attorney General Counsel’s Office-MQA Practitioner Regulation-Legal | COUNSEL FOR PETITIONER: “Deborah Loucks,s . CCA: ~1-\o-2uxes . Senior Attorney PLO Mendzeu, Shygis OPoue ~~ Florida Bar Number 0169889_ _ Agency for Health Care Administration Practitioner Regulation-Legal Post Office Box 14229 Tallahassee, Florida 32317-4229 Phone: (850) 487-9694 © DL/st 04/14/00 cer emerge ome pete

Docket for Case No: 00-002534