Hs, Rick Scott yo @,= State of Florida Governor Department of Children and Families Mike Carroll Secretary Dennis Miles Regional Managing Director August 16, 2017 CERTIFIED MAIL: 9171 9696 0935 0156 192151 To: London Treatment Center of Florida, LLC 1551 Forum Place, Bldg.300, Suites C, D and E West Palm Beach, Florida 33401 ADMINISTRATIVE COMPLAINT YOU ARE HEREBY NOTIFIED of the Department of Children and Families’ intent to seek permanent revocation of London Treatment Center of Florida, LLC’s license to operate a substance abuse treatment facility. The Department’s authority and grounds are as follows: London Treatment Center of Florida, LLC, is licensed under Chapter 397 Fla. Stat. and Chapter 65D-30 Fla. Admin. Code to operate at 1551 Forum Place, Bldg. 300, Suites C, D and E, West Palm Beach, Florida 33401. They are operating under license number 5047252787801 to provide the following treatment components: Day or Night Treatment, Intensive Outpatient Treatment and Outpatient Treatment, effective pursuant to issuance of a license renewal on October 23, 2016, for a period of one year. 1. The Department is authorized by section 397.415(1)(d)(2) Fla. Stat. to revoke the license of a service provider for, “An intentional or negligent act materially affecting the health or safety of an individual receiving services from the provider.” Circuit 15 111 So. Sapodilla Avenue, West Palm Beach, Florida 33401 Mission: Work in Partnership with Local Communities to Protect the Vulnerable, Promote Strong and Economically Self-Sufficient Families, and Advance Personal and Family Recovery and Resiliency The owners and operators of London Treatment Center obtained the above referenced license and then engaged in illegal and fraudulent activities and business practices in operating the facility. These actions have had a direct adverse impact on patient wellbeing and treatment as the owners of the treatment facility are charged with multiple accounts of patient brokering, whereby victimizing the clients they were licensed to serve. London Treatment Center has two owner/operators: Mark Johnston and Jordi Martinez. Mr. Johnston is also the designated Chief Executive Officer and Mr. Martinez serves as the Chief Financial Officer. Mr. Johnston and Mr. Martinez have both been arrested and charged with sixty-two counts of Patient Brokering in violation of section 817.505(1)(a)(4) Fla. Stat. Each of the sixty-two counts is a third degree felony, carrying a maximum penalty of five years in the Department of Corrections. The victims of these crimes arc those clients who are to be served at London Treatment Center pursuant to the license issued by the Department. . These actions have created an immediate danger to the health, safety and welfare of patients, their families and communities, and have undermined the essential integrity of treatment and patient safety at this facility. . Both Johnston and Martinez were arrested on site at the London Treatment Center on July 12, 2017. The state attorney has formally charged both by the filing of an information delineating the sixty-two counts of patient brokering. The charges demonstrate that there is an immediate threat and immediate serious danger to the health, safety and welfare of those who are seeking substance abuse treatment, their families and communities. . Their criminal behavior and enterprise, resulted in no bond holds being placed on each individual. . The narratives of the Probable Cause Affidavits and the Information filed clearly depict the impact of the criminal behavior of Johnston and Martinez had on the vulnerable clients that were seeking treatment at the London Treatment Center. There is an immediate and genuine concern for the citizens in this community, especially those seeking substance abuse treatment at this facility. Due to the intentional, negligent, and criminal conduct described above, the Department intends to permanently revoke London Treatment Center’s license number 5047252787801 to operate a substance abuse treatment facility. we (intentionally left blank) NOTIFICATION OF RIGHTS UNDER CHAPTER 120, FLORIDA STATUTES IF YOU BELIEVE THE DEPARTMENT’S DECISION IS IN ERROR, YOU MAY REQUEST AN ADMINISTRATIVE HEARING UNDER SECTIONS 120.569 AND 120.57, FLORIDA STATUTES, TO CONTEST THE DECISION. YOUR REQUEST FOR AN ADMINISTRATIVE HEARING MUST BE RECEIVED BY THE DEPARTMENT BY 5:00, P.M., NO LATER THAN 21 CALENDAR DAYS AFTER YOU RECEIVED THE DEPARTMENT’S ADMINISTRATIVE COMPLAINT. You must submit your request for an administrative hearing to the Department at the following addresses: Colleen Farnsworth Regional Legal Counsel Florida Department of Children and Families 111 South Sapodilla Ave., Suite 303 West Palm Beach, FL 33401 IF YOUR REQUEST FOR AN ADMINISTRATIVE HEARING IS NOT RECEIVED BY THE DEPARTMENT BY THE ABOVE DEADLINE, YOU WILL HAVE WAIVED YOUR RIGHTS TO A HEARING AND THE DEPARTMENT’S PROPOSED ACTION WILL BE FINAL. ANY DENIAL, SUSPENSION, REVOCATION OR OTHER ACTION CONCERNING YOUR LICENSE OR REGISTRATION WILL BE EFFECTIVE ON THAT DATE OR ON ANY LATER EFFECTIVE DATE STATED IN THE ADMINISTRATIVE COMPLAINT, AND ANY PENALTY OR FINE IMPOSED MUST BE PAID WITHIN 30 DAYS THEREAFTER OR ANY EARLIER TIME PROVIDED IN THE ADMINISTRATIVE COMPLAINT. If you disagree with the facts stated in the Department’s administrative complaint, you may request a formal administrative hearing under section 120.57(1), Florida Statutes. At a formal hearing, you may present evidence and arguments on all issues involved, and question the witnesses called by the Department. You have the right to be represented by counsel or other qualified representative. If you do not disagree with the facts stated in the Department’s administrative complaint, you may request an informal administrative hearing under section 120.57(2), Florida Statutes. At an informal hearing, you may present your argument or a written statement for consideration by the Department. You have the right to be represented by counsel or other qualified representative. Your request for an administrative hearing must meet the requirements of Rule 28-106.2015(5), Florida Administrative Code, must be prepared legibly on 8% by 11 inch white paper, and include all of the following items: (a) Your name, address, email address (if any) and telephone number. (b) The name, address, email address (if any) and telephone number of your attorney or qualified representative, if any. ({c) A statement requesting an administrative hearing. (d) A statement of all facts in the administrative complaint with which you disagree. If you do not disagree with any of the facts stated in the administrative complaint, you must say so. (e) A statement of when and how you received the administrative complaint. () A statement identifying the file number of the administrative complaint, if shown on the administrative complaint. Section 120.569, Florida Statutes, and rule 28-106.201(4), Florida Administrative Code, require the Department to dismiss your request for hearing if it is not in substantial compliance with the requirements above. Mediation as described in section 120.573, Florida Statutes, is not available. However, other forms of mediation or informal dispute resolution may be available after a timely request for an administrative hearing has been received, if agreed to by all parties, and on such terms as agreed to by all parties. The right to an administrative proceeding is not affected when mediation or informal dispute resolution does not result in a settlement. CERTIFICATE OF SERVICE Copies furnished to the following via Hand delivery to London Treatment Center of Florida LLC, operating at 1551 Forum Place, 300 Suites C, D & E, West Palm Beach, Florida 33401, and/or by email to Jeffrey Lynne, Esq, at jlypne@bmulaw.com on this the 16th day of August, 2017

Docket for Case No: 17-005115