STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, ve CASE NO. 2018-28240 BONNIE WELLS, L.C.S.W. RESPONDENT. / ADMINISTRATIVE COMPLAINT Petitioner Department of Health (Department) files this Administrative Complaint before the Board of Clinical Social Work, Marriage and Family Therapy, and Mental Health Counseling (Board) against Respondent Bonnie ’ Wells, L.C.S.W., and in support thereof alleges: 1. Petitioner is the state agency charged with regulating the practice of licensed clinical social workers pursuant to Section 20.43, Florida Statutes (2018); and Chapter 456 and Chapter 491, Florida Statutes (2018). 2. Atall times material to this Complaint, Respondent was licensed to practice as a clinical social worker within the State of Florida, having been issued license number SW 7775. 2. — At all times material to this Complaint, Respondent’s address of record was 2300 Bluff Oak Way, Apartment 1301, Tallahassee, Florida 32311. 3. On or about October 18, 2018, the Department issued an Order Compelling Examination (Order). | 4. The Order required Respondent to report and submit to a mental and physical examination to be conducted by T. Roland Reeves, M.D., on December 7, 2018, at 9:45 a.m. 5. The Department served the Order on November 21, 2018. 6. On December 7, 2018, Respondent failed to report and submit to the examination as ordered. 7. Section 456.072(1)(q), Florida Statutes (2018), authorizes the Board to impose discipline for violating a lawful order of the department or board, or failing to comply with a lawfully issued subpoena of the department. 8. Respondent violated a lawful order of the Department by failing to report and submit to an evaluation with T. Roland Reeves on December 7, 2018. 9. Based on the foregoing, Respondent violated Section 456.072(1)(q), Florida Statutes (2018). Administrative Complaint Dep't of Health v. Bonnie Wells, L.C.S.W. Case Number 2018-28240 WHEREFORE, Petitioner respectfully requests that the Board enter an order imposing one or more of the following penalties: permanent revocation or suspension of Respondent's license, restriction of practice, imposition of an administrative fine, issuance of a reprimand, placement of Respondent on probation, corrective action, refund of fees billed or collected, remedial education and/or any other relief that the Board deems appropriate. JHA SIGNED this [4™ day of _poveousler 2019. Respectfully submitted, wulel ©. Gerald Henley FILED DEPARTMENT OF HEALTH Assistant General Counsel DEPUTY CLERK FL DOH Prosecution Services Unit CLERK: (diene Worn 4052 Bald Cypress Way, Bin C-65 DATE: DEC 17 2019 Tallahassee, FL 32399-3265 Florida Bar Number 1005574 (P) (850) 558-9832 (F) (850) 245-4662 (E) gerald. henley @flhealth.gov PCP Meeting: December 12, 2019 PCP Members: Sandra Barlow & Denny Cecil-Van Den Heuvel Administrative Complaint Dep't of Health v. Bonnie Wells, L.C.S.W. Case Number 2018-28240 NOTICE OF RIGHTS Respondent has the right to request a hearing to be conducted in accordance with Section 120.569 and 120.57, Florida Statutes, to be represented by counsel or other qualified representative, to present evidence and argument, to call and cross-examine witnesses and to have subpoena and subpoena duces tecum issued on his or her behalf if a hearing is requested. A request or petition for an administrative hearing must be in writing and must be received by the Department within 21 days from the day Respondent received the Administrative Complaint, pursuant to Rule 28-106.111(2), Florida Administrative Code. If Respondent fails to request a hearing within 21 days of receipt of this Administrative Complaint, Respondent waives the right to request a hearing on the facts alleged in this Administrative Complaint pursuant to Rule 28-106,111(4), Florida Administrative Code. Any request for an administrative proceeding to challenge or contest the material facts or charges contained in the Administrative Complaint must conform to Rule 28-106.2015(5), Florida Administrative Code. Mediation under Section 120.573, Florida Statutes, is not available to resolve this Administrative Complaint. NOTICE REGARDING ASSESSMENT OF COSTS Respondent is placed on notice that Petitioner has incurred costs related to the investigation and prosecution of this matter. Pursuant to Section 456.072(4), Florida Statutes, the Board shall assess costs related to the investigation and prosecution of a disciplinary matter, which may include attorney hours and costs, on the Respondent in addition any other discipline imposed. Administrative Complaint Dep't of Health v. Bonnie Wells, L.C.S.W. Case Number 2018-28240

Docket for Case No: 20-001281PL