Just because the shoe is off the court does not mean the play is safe. What about the girl jumping up and down without a shoe. She could slip and fall. She could get her foot stepped on. I would kill it. The same as I would if a ball rolled on the court.
If it was a repeated problem, then I would assess a UD and go from there but I have never seen a player intentionally loose a shoe. At least not yet :-)
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