STATE OF FLORIDA BOARD OF CLINICAL SOCIAL WORK, MARRIAGE AND FAMILY THERAPY AND MENTAL HEALTH COUNSELING DEPARTMENT OF HEALTH, PETITIONER, v. CASE NO. 2019-18590 - SHAWN MARIE NORTH, L.C.S.W., RESPONDENT. / ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, Department of Health, and files this Administrative Complaint before the Board of Clinical Social Work, Marriage and Family Therapy, and Mental Health Counseling against Respondent, Shawn Marie North, L.C.S.W., and alleges: 1. Petitioner is the state agency charged with regulating the practice of Clinical Social Work, Marriage and Family Therapy and Mental Health Counseling pursuant to section 20.43, Florida Statutes; chapter 456, Florida Statutes; and chapter 491, Florida Statutes. 2. At all times material to this Complaint, Respondent was a licensed clinical social worker in the State of Florida, having been issued license number SW 14061. 3. Respondent's address of record is 1305 Rustling Oaks Drive, Brandon, Florida 33510. 4. On or about March 21, 2018, Respondent began treatment of Patient M.D, 5. On or about the morning of April 11, 2019, M.D. passed away. 6. On or about April 14, 2019, Respondent submitted a therapy Progress Note stating she had a therapy session with M.D. at or about 3:30 PM, April 11, 2019. 7. On or about April 22, 2019, Respondent submitted a therapy Progress Note stating she had a therapy session with M.D. on April 17, 2019. 8. On or about April 29, 2019, Respondent submitted a therapy Progress Note stating she had a therapy session with M.D. on April 25, 2019. 9. Respondent filed a false report or record by filing progress notes that stated Respondent provided therapy to M.D. on the afternoon of April 11, 17%, and 25", 2019, all of which would were dates and times occurring after M.D. passed away. 10. Section 491.009(1)(i), Florida Statutes (2018), subjects a licensed mental health counselor to discipline for willfully making or filing a false report or record. DOH v. SHAWN MARIE NORTH, L.C.S.W. DOH Case # 2019-18590 Page 2 of 5 11. Respondent willfully filed false reports on or about April 14", April 22%, and 29", 2019. 12. Based on the foregoing, Respondent violated Section 491.009(1)(i), Florida Statutes (2018). WHEREFORE, the 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 the Respondent on probation, corrective action, refund of fees billed or collected, remedial education and/or any other relief that the Board deems appropriate. [SIGNATURE ON NEXT PAGE] DOH v. SHAWN MARIE NORTH, L.C.S.W. DOH Case # 2019-18590 Page 3 of 5 SIGNED this 12" day of March, 2020. Scott A. Rivkees, MD State Surgeon General DEPARTMENT OF HEALTH ; DEPUTY CLERK Assistant GéfheraPCounsel CLERK: a ud Florida Bar No. 117940 Mos DOH Prosecution Services Unit DATE: __MA® 1 3 nog 4052 Bald Cypress Way Tallahassee, FL 32399-3265 Telephone (850) 558-9862 Ryan.Sandy@flhealth.gov PCP Date: 3/11/20 PCP Members: Bolhouse and Otis DOH v. SHAWN MARIE NORTH, L.C.S.W. DOH Case # 2019-18590 Page 4 of 5 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. Please be advised that mediation under Section 120.573, © Florida Statutes, is not available for administrative disputes involving this agency action. 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 to any other discipline imposed. DOH v. SHAWN MARIE NORTH, L.C.S.W. DOH Case # 2019-18590 Page 5 of S

Docket for Case No: 21-000572PL